Credit union groups: FinCEN reporting requirements are outdated

Reporting threshold is too low, regulatory burden too high

The Financial Crimes Enforcement Network’s requirements that credit unions and banks file Suspicious Activity Reports (SARs) for transactions exceeding $5,000 are burdensome and out of date, credit union trade groups told the network earlier this month.

“While larger banks and non-bank mortgage lenders can afford to absorb the significant regulatory and compliance costs from the [anti-money laundering and terrorist financing] framework, these rules have made it significantly more difficult for credit unions to provide the affordable financial services credit union members depend on and deserve,” Luke Martone, senior director of advocacy and counsel, at America’s Credit Unions wrote, in a comment submitted to FinCEN.

Martone and officials from the Virginia Credit Union League urged FinCEN officials to increase the threshold for transactions that trigger a SAR from $5,000 to $10,000, saying the threshold was established many years ago.

Under the federal Paperwork Reduction Act, agencies periodically request public comment on information collection requirements. As part of a Paperwork Reduction Act filing earlier this year, FinCEN said that it planned no changes to the current SAR filing process. The network also estimated that the filing of a SAR should take a financial institution two hours.


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