WASHINGTON (11/17/11)--Credit unions with less than $50 million in assets should be exempt from the Financial Crimes Enforcement Network's (FinCEN) new Bank Secrecy Act (BSA) electronic filing requirements, and those that that demonstrate substantial core-processing or system costs should also be allowed to waive the rules, the Credit Union National Association (CUNA) said in a comment letter.
The Credit Union National Association (CUNA) has urged the Financial Crimes Enforcement Network (FinCEN) to provide a waiver for credit unions that demonstrate substantial core processing or system costs and, in addition, exempt credit unions with under $50 million in assets, from the terms of potential new Bank Secrecy Act (BSA) electronic filing requirements.
FinCEN earlier this year said it is considering making electronic filing of all BSA reports mandatory, starting on June 30, 2012.
CUNA, in its comment letter, said it supports FinCEN's work to provide law enforcement with more useful and timely BSA data, and has encouraged credit unions to use electronic filing features. However, CUNA said, there are compliance and implementation cost concerns.
CUNA said credit unions "could incur significant costs to meet the requirements of the proposal, including upgrades to their core processing systems and training." CUNA urged FinCEN to work with the National Credit Union Administration (NCUA), state regulators, and third-party vendors "to minimize compliance costs related to the proposal."
FinCEN has said the switch to all-electronic BSA filing would improve efficiency, reduce costs for the financial industry, and enhance the ability of investigators, analysts, and examiners to gain better and more timely access to important financial information.
Increased BSA E-Filing would also help FinCEN provide information relevant to money laundering and terrorist financing investigations to law enforcement in the quickest manner possible, shortening the lag time between when BSA reports are filed and when they can be accessed by authorities to two days.
For the full CUNA comment letter, use the resource link.