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CUNA Regulatory Comment Call

April 23, 2009

EXECUTIVE SUMMARY

• FinCEN, NCUA and the other federal banking agencies issued a notice and request for comments on the Suspicious Activity Report to gauge the success of their continuing effort to reduce paperwork and burden in information collections.
• FinCEN, NCUA and the other federal banking agencies are seeking comment on the currently approved Suspicious Activity Report by Depository Institutions, which is being renewed without change.
• Please submit your comments to CUNA by May 20, 2009. Comments are due to FinCEN by June 1, 2009.

Please feel free to fax your responses to CUNA at 202-638-7052; email them to Senior Vice President and Deputy General Counsel Mary Dunn at mdunn@cuna.com or to Federal Compliance Counsel Nichole Seabron at nseabron@cuna.com; or mail them to Mary or Nichole in c/o CUNA’s Regulatory Affairs Department, 601 Pennsylvania Avenue, NW, South Building, Suite 600, Washington, DC 20004. You may also contact us at 800-356-9655 ext 6739, if you would like a copy of the proposed rule or you may access here.

BACKGROUND

FinCEN and the Banking Supervisory Agencies, as part of their continuing effort to reduce paperwork and respondent burden, invite the general public and other Federal agencies to take this opportunity to comment on information collections required under the Bank Secrecy Act’s Suspicious Activity Reporting requirements. The regulators are soliciting comments concerning the currently approved Suspicious Activity Report by Depository Institutions, which are being renewed without change.

• Are there any changes that could be made to the Suspicious Activity Report that would make form filing more efficient? For example, can you suggest a better process for filing amended forms?
  
  

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• Is Suspicious Activity Report filing in its current form a burdensome process for your credit union? If so, please be specific in describing the burden of SAR filing on your credit union.
  
  

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• Other comments?
  
  

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