Compliance: FinCEN seeks comments on proposed CTR changes

February 8, 2016

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:

  • Shared branching simplifications. For situations where the filing credit union may not know the employer identification number (EIN) of the credit union where the transaction was conducted, an “unknown” check box has been added;
  • When the filing and transaction location differ, a new Part IV has been added to record the entity actually filing the report through the Bank Secrecy Act (BSA) e-filing system;
  • When the filing and transaction location are the same, a check box has been added to Part III to indicate when the information in Parts III and IV are the same, and the completion order of the form has been revised. Part IV will be first, followed by Part III (allowing effective use of the check box), then Part I, and finally Part II; and
  • Multiple transactions. Cash-in and cash-out fields have been added to Part III to support recording the dollar amount of the transaction at the transaction location.

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

CUNA’s CompBlog looked into the issue as well, and credit union compliance staff can find more information on this and other compliance issues at CUNA’s Compliance Community.