SAR, CTR modernizations needed

Ahead of a hearing to evaluate the Financial Crimes Enforcement Network (FinCEN) this week, America’s Credit Unions urged Congress to update outdated thresholds for reporting suspicious activity reports (SARs) and currency transaction reports (CTRs).  

“America’s Credit Unions supports Representative Loudermilk’s bill, the Financial Reporting Threshold Modernization Act (H.R. 1799), which updates the CTR threshold from $10,000 to $30,000, increases the SAR threshold from $5,000 to $10,000, and ensures the CTR threshold is periodically adjusted for inflation.” wrote President/CEO Jim Nussle in a letter outlining this request and more. “Such increases would be conservative, appropriate, and more properly strike a balance between what is helpful to law enforcement and the compliance burden for credit unions.”  

He also identified CTR aggregation as a significant challenge for credit unions, citing the tracking required as an “often manual, resource-intensive process.”

“America’s Credit Unions further supports streamlining CTR and SAR data fields to reduce redundancies, eliminate confusion, and allow the use of templates for common or recurring typologies,” he added.  

Nussle previously engaged the House Rules Committee on this issue, urging them to add the SAR and CTR modernization legislation proposed by Rep. Loudermilk, R-Ga., as an amendment to the National Defense Authorization Act. In addition, America's Credit Unions was the sole credit union industry representative at a Treasury roundtable on this issue in August. Head of Compliance Marilyn Barker and Regulatory Advocacy Senior Counsel Luke Martone took part in the high-level discussions that included representatives from the FBI and Department of Homeland Security.

America’s Credit Unions will continue to engage lawmakers and the Treasury Department to advocate for needed modernization that will help credit unions better serve their members.