WASHINGTON,, DC (December 2, 2025) |
Yesterday, the Defense Credit Union Council, DCUC, sent a letter to the Financial Crimes Enforcement Network (FinCEN) supporting the proposed renewal, without changes, of existing Bank Secrecy Act (BSA) information-collection requirements governing information sharing between government agencies and financial institutions.
Under FinCEN’s Section 314(a) process, financial institutions must review their records upon request to determine whether they have maintained accounts or conducted transactions with individuals or entities identified by the government. If so, they must report this information within the specified timeframe.
DCUC commends FinCEN’s commitment to a strong information-sharing framework and agrees that the current collection requirements are necessary, useful, and generally manageable for credit unions.
“We support the renewal of this information collection without change,” said Jason Stverak, DCUC Chief Advocacy Officer. “Nevertheless, FinCEN can enhance the quality, utility, and clarity of the information collected and minimize the burden of the collection of information on respondents. We encourage FinCEN to engage with credit unions and to invest in resources focused on supporting smaller and mid-sized credit unions that may have less staffing and technological capabilities than larger financial institutions have.”
DCUC advised that additional support, such as implementation guides, periodic training, compliance checklists, and readily accessible points of contact, would reduce compliance burdens and improve the value of the information collected.
As FinCEN evaluates future BSA compliance burdens, DCUC notes that credit unions may frequently need clarification on Section 314(a) Requests. Clearer contact information and faster response times from designated Points of Contact would further streamline the process.
DCUC looks forward to continued collaboration with FinCEN to strengthen communication and support across the credit union industry.