Failure to modernize BSA thresholds adds unnecessary compliance burden

March 24, 2021

CUNA supports legislation from Rep. Barry Loudermilk (R-Ga.) that would modernize Bank Secrecy Act (BSA) reporting thresholds for the first time since 1970. The bill is the Financial Reporting Threshold Modernization Act (H.R. 2040).

“The failure to modernize the reporting thresholds has led to the imposition of an unnecessary compliance burden on many credit unions due to the obligation to collect and report nonsuspicious information,” the letter reads.

H.R. 2040 would increase the Currency Transaction Report (CTR) threshold of $10,000 to an updated $30,000. The legislation would also increase the dollar amount thresholds for filing Suspicious Activity Reports (SARs) from $5,000 to $10,000 for most financial institutions and $2,000 to $3,000 for money service businesses.

CUNA supports H.R. 2040’s goal to narrowly tailor when and how reports of suspicious financial activity are triggered to reduce low-value reporting while maintaining financial inclusion.

“While CUNA supports the objectives of laws and regulations to combat illicit financing, the current policies negatively impede 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,” the letter reads. “This is burdensome and unwieldy and dilutes the intent of the BSA.”