CUNA
  • Advocacy
    • Priorities we’re fighting for
    • Actions you can take
  • News
  • Learn
  • Compliance
  • Shop
  • Topics
    • Community Service
    • Compliance
    • Credit Union Hero
    • Credit Union Rock Star
    • Credit Union System
    • Directors
    • Human Resources
    • Leadership
    • Lending
    • Marketing
    • Operations
    • Policy & Issues
    • Sales & Service
    • Technology
  • Credit Union Magazine
    • Buyers' Guide
    • COVID-19
    • Digital Edition
    • Credit Union Hero
    • Credit Union Rock Star
    • Subscribe
    • Advertise
    • Contact
  • COVID-19
  • Advertise
  • Awards
    • Nominate Credit Union Hero
    • Nominate Credit Union Rock Star
  • Podcasts
  • Videos
  • Contact
Learn More about Member Value

News

Member Benefits
Learn more
Learn more about the benefits of membership.
Home » Lower BSA transfer threshold would substantially burden CUs
Policy & Issues

Lower BSA transfer threshold would substantially burden CUs

November 30, 2020
Fed

A proposed reduction in the threshold for Bank Secrecy Act (BSA) regulatory information collection, retention and transmittal requirements for funds transfers would result in substantial burdens and costs for credit unions, CUNA wrote to the Federal Reserve and Financial Crimes Enforcement Network (FinCEN). The two agencies proposed lowering the reporting thresholds for certain transfers and transmittals to $250, well below the current $3,000.

“It is critically important to strike the right balance between the imposition of compliance costs on leanly staffed, community-oriented credit unions and the potential benefits that BSA regulatory requirements may provide to law enforcement,” the letter reads. “In its current form, this proposed rule fails to strike that balance…[b[ecause the proposed rule contemplates a dramatic 91% reduction in the collection, retention and transmission threshold, CUNA believes that it will burden a larger number of credit unions, particularly those serving disadvantaged immigrant communities.”

The proposal states the revisions would impact at least 5,236 credit unions, 4,681 of which are federally regulated small credit unions.

CUNA also stated that the proposal does not adequately consider alternative approaches. 

“CUNA has consistently advocated for minimizing the duplication of various BSA regulations and improving feedback on SARs to ensure they are truly beneficial to law enforcement,” the letter adds.

KEYWORDS BSA
Credit Union Magazine - Spring 2021

Spring 2021

Credit Union Magazine’s Spring 2021 edition features CUNA's 2021 advocacy agenda, strategic planning guidance, and labor market insights.
Digital Edition •  Subscribe

Trending

  • Cheryl Deborde named Credit Union Hero of the Year

  • PCA flexibility coming soon from NCUA

  • CFPB proposes delayed effective date for recent debt collection rules

Tweets by CUNA_News

Polls

How have vaccination efforts affected your remote work policy?

View Results
More

Champion of America’s Credit Unions

Credit Union National Association is the only national association that advocates on behalf of all of America’s credit unions. We work tirelessly to protect your best interests in Washington and all 50 states. We fuel your professional growth at every level and champion the credit union story at every turn.

More CUNA

  • About
  • Careers
  • Contact Us
  • Recommended Websites
  • Privacy Policy

Resources for

  • CUNA Board Members
  • Credit Union Advocates
  • Leagues
  • Press
  • Vendors