WASHINGTON—CUNA said it strongly supports the Financial Crimes Enforcement Network's (FinCEN) efforts to conduct a review of the Bank Secrecy Act, sharing several examples of burdens the trade group said BSA places on credit unions.
FinCEN issued the review to solicit comment on how to streamline, modernize, and update anti-money laundering requirements in the Bank Secrecy Act.
“The burdens created by BSA framework and the AML/CFT regime are significant. These requirements often impose significant compliance cost related to software and staffing, and consume large quantities of staff time, especially where manual processes are involved,” CUNA wrote in a letter to FinCEN. “Given the tremendous expenditure of resources, it is reasonable and appropriate for FinCEN to conduct this review, and future reviews on a regular basis.”
CUNA called for Suspicious Activity Reports (SAR) and Currency Transaction Reports (CTRs) to be modernized, saying they are among the most “burdensome and time consuming” for all BSA/AML programs.
Additional Recommendations
According to CUNA, this includes the thresholds for filing CTRs and SARs, which are the same amount as when the BSA was enacted in 1972. The trade group added it supports legislation—the Financial Reporting Threshold Modernization Act—which would raise CTR and SAR reporting thresholds.
The letter also recommends FinCEN:
- Issue information on what information from SARs are most useful to law enforcement
- SAR and CTR forms should combined into one form and submitted to a single place
- Revisit the requirement to file marijuana limited SARs
- Update its guidance to clearly and concisely state 314(b) communication can be shared for all suspected financial crimes and BSA violations
Give Us Less Than 1 Minute & We’ll Give You Good News!
The ongoing popularity of CUToday.info’s daily Fresh Today newsletter has led to a need to move to a new server in order to provide improved service to our readers. In order to continue to receive the daily email, you must register by March 7. To register, just click here. The daily Fresh Today news headlines email remains FREE! The new service is being launched as part of a partnership with ResponseGenius.