Adjustments would bring add’l accuracy in determining CTR costs

July 13, 2020

CUNA supports the Treasury’s Financial Crimes Enforcement Network (FinCEN) updating the Paperwork Reduction Act (PRA) burden estimates from complying with a Bank Secrecy Act (BSA) requirement for financial institutions to report transactions in currency of more than $10,000 using a Currency Transaction Report (CTR). The proposed updates do not affect credit unions, rather they change the PRA analysis for new CTR rulemakings.

“Adjustment to the PRA burden calculation will lead to greater accuracy in detailing the true cost to a financial institution for filing a CTR,” the letter reads. “We agree that the two additions to the PRA burden calculation are relevant in determining the entire cost for filing CTRs. The cost to obtain data required by the report that the filer does not need for its own bookkeeping, and maintaining, updating, and upgrading the technological infrastructure required to file and store the report are a necessary addition to the PRA calculation.”

CUNA adds that the above costs are “critical in determining the true costs for filing CTRs” and having the most accurate PRA burden calculation for CTRs is important as financial institutions expend vast resources filing these reports.

“Understanding this complete burden is an important step in determining whether the information gathered from CTRs is worth the cost to financial institutions to produce the report,” the letter reads.