WASHINGTON (3/30/16)--The Credit Union National Association (CUNA) supports most proposed changes to the layout of the Bank Secrecy Act Currency Transaction Report (BCTR). In a comment letter filed with the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN), CUNA also noted that any regulatory changes--even absent additional requirements--may cause credit unions to expend time and resources to comply with a change.
CUNA also used the letter to push for greater regulatory and examination consistency among regulators, including the National Credit Union Administration, state credit union regulators and FinCEN.
“We continue to hear of instances in which different regulators and examiners interpret BSA requirements and guidance differently, which makes it difficult for credit unions to satisfy examiners and plan accordingly throughout their organizations,” the letter reads. “Greater consistency would also be helpful with the interpretation of requirements regarding BSA reports.”
CUNA also encouraged FinCEN to increase the BCTR threshold to $20,000 from the $10,000 level established decades ago, and to at least double other key thresholds, such as the $3,000 trigger for reporting wire transfers and $5,000 threshold for filing a Suspicious Activity Report (SAR).
BCTRs are used by financial institutions to report transactions of more than $10,000 occurring in a single day by or on behalf of one person. The reports are accessible to law enforcement investigating money laundering, terrorist financing or other financial-based crimes.
Since publishing a revised BCTR in March 2011, FinCEN has become aware that the current report is not configured to allow for alternative reporting models that have developed in recent years, such as reports filed by a parent company. In addition, the current form was not designed to record different filing and transaction locations.
CUNA supports FinCEN’s objective of improving the tracking of money laundering and terrorist financing, but has a number of comments regarding the proposed changes.