BSA modernization bill ‘long overdue,’ CUNA says in letter of support

January 31, 2019

CUNA wrote in support of a bill Thursday that would update thresholds for certain reporting thresholds contained in the Bank Secrecy Act (BSA). The bill, H.R. 388, was introduced by Rep. Barry Loudermilk (R-Ga.), and would raise reporting thresholds for institutions filing Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs).

“The dollar amount reporting thresholds contained in the Bank Secrecy Act have not been updated since the law was first enacted in 1970,” the letter reads. “In the nearly fifty years that have since passed, the $10,000 established as a reporting threshold under the law has become the buying power equivalent of more than $66,000—according to the Consumer Pricing Index’s Inflation Calculator provided by the Bureau of Labor and Statistics.”

H.R. 388 would increase the threshold for filing a CTR to $30,000 (up from the current $10,000) and for filing a SAR to $10,000 and $3,000 (up from $5,000 and $2,000, respectively).

“CUNA appreciates the goal of this legislation to narrowly tailor when and how reports of suspicious financial activity are triggered to reduce low-value reporting while maintaining financial inclusion,” the letter reads. “While CUNA supports the objectives of laws and regulations to combat illicit financing, the current regime negatively impedes the ability of credit unions to engage in ordinary lending and consumer finance, while also serving to inundate law enforcement with informational paperwork on transactions that credit union employees know to be legitimate, but for the legal requirement to file reports.”