Streamlining CTR, SAR reporting would ease burdens, aid law enforcement
Following up on credit union concerns raised during the Treasury roundtable on Currency Transaction Report/Suspicious Activity Report (CTR/SAR) modernizations earlier this month, America’s Credit Unions wrote to Treasury Secretary Scott Bessent on Friday. The letter continued the organization’s collaboration with Treasury and other stakeholders to modernize these processes. America’s Credit Unions and its members support modernizing CTR and SAR reporting thresholds while sharing Treasury’s goal to ensure reporting remains effective for law enforcement and sustainable for credit unions of all sizes.
The letter notes credit unions consistently identify CTR and SAR filings as one of the most significant ongoing challenges.
“We strongly support streamlining CTR and SAR data fields to remove redundancies and clarify confusing items and perhaps permitting the use of templates for certain redundant instances and typologies of financial crimes, thereby improving reporting quality.”
Specific recommendations include:
- Support raising the CTR reporting threshold and index it to inflation or use a risk-tiered threshold based on transaction amount and risk. America’s Credit Unions supports legislation from Rep. Barry Loudermilk, R-Ga., that would update the CTR threshold to $30,000 (up from the current $10,000) and periodically adjust it for inflation;
- Considering simplified “CTR-Lite” and “SAR-Lite” processes for long-standing, low-risk members, along with extending filing windows for smaller credit unions;
- Adding enhanced categories with clear checkboxes and fraud-type categories, including cryptocurrency scams, money-mule activity, and romance scams to improve tracking and detection; and
- Creating a secure feedback dashboard or interface showing which SARs are most useful to law enforcement, and exploring a safe harbor for credit unions using approved artificial intelligence or machine learning models within that interface.
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