CUNA to Senate Committee: BSA/AML relief needed

November 29, 2018

CUNA supports efforts to track money laundering and terrorist financing but also believe it's important to strike the balance between the costs to financial institutions and the benefits to the federal government it wrote Thursday. CUNA sent its letter for the record of a Senate Banking Committee hearing on combating illicit finance.

“We encourage a regulatory regime that recognizes the time and effort that goes into good faith compliance with laws, and does not unduly punish financial institutions for unintentional technical or minor errors,” the letter reads. “The seemingly never-ending stream of regulatory expectations for credit unions, often with small and stretched staffs, must be considered in agency examinations and when laws and requirements are enacted.”

Specifically, CUNA supports changes to:

  • Minimize the duplication of the same or similar information;
  • Provide additional flexibility based on the reporting institution type or level of transactions;
  • Curtail the continually enhanced customer due diligence requirements;
  • Increase the threshold requiring Currency Transaction Reports (CTRs);
  • Reduce and simplify the reporting requirements of Suspicious Activity Reports (SARs) that have limited usefulness to law enforcement; and
  • Allow for greater regulatory and examination consistency among regulators, including NCUA and state credit union regulators, in order to help with interpretations of BSA requirements and guidance and to minimize regulatory overlap.