WASHINGTON (2/8/16)--To remedy perceived limitations of the Currency Transaction Report (CTR), the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) is seeking comments on potential changes to the form. Comments are due by April 4.
According to FinCEN, this is primarily due to the fact that, since the current form was published in March 2011, the current report is not configured to allow for alternative reporting models that have developed since then.
Proposed changes include:
The Credit Union National Association (CUNA) has received increasing numbers of questions about CTRs, particularly since e-filing went into effect in 2012. And while CUNA may be pleased to see efforts to simplify the form, it hopes to see further improvements in the future.
CUNA’s BSA working group sent a number of ideas for improvements to FinCEN’s BSA advisory group last fall, requesting form simplifications, and an increase in in the CTR threshold to $20,000 from the current $10,000.
The working group noted that $20,000 in 2015 money is lower than the rate of inflation since 1986 when the $10,000 threshold was originally issued.
Credit unions with thoughts and concerns about the proposed changes can contact CUNA Senior Director of Advocacy and Counsel Luke Martone at firstname.lastname@example.org.