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| Recommending Congressional actions to modernize BSA |
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Modernizing and improving the efficacy of the Bank Secrecy Act (BSA) and other laws would enhance consumer safety while providing needed regulatory relief for consumers America’s Credit Unions told Congress yesterday. In advance of a House Financial Services subcommittee hearing on modernizing the BSA, America’s Credit Unions wrote to the Committee to provide several recommendations for Congressional actions to help credit unions.
These recommendations include:
• Modernizing the Currency Transaction Report (CTR) and Suspicious Activity Report (SAR) thresholds. Rep. Barry Loudermilk, R-Ga., introduced a bill to increase the CTR threshold to $30,000, the SAR threshold to $10,000, and periodically adjust the CTR threshold for inflation;
• Simplifying CTR and SAR forms and filing processes to include updating data fields to remove redundancies and clarify confusing items, as well as permitting the use of templates for certain redundant instances and typologies of financial crimes;
• Streamlining reporting options, such as a simplified “CTR-Lite” process for long-standing, low-risk members, along with extending filing windows for smaller credit unions;
• Formalizing the Customer Due Diligence-related relief issued in February;
• Revisiting the Financial Crimes Enforcement Network (FinCEN) requirement to file marijuana limited SARs. If the requirement cannot be eliminated entirely, FinCEN should consider allowing credit unions to file marijuana limited SARs once a year; and
• Improving the quality and completeness of identifiers included in 314(a) requests, including taxpayer identification number, passport number, date of birth, or address.
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