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Removing Barriers Blog

CUNA Writes in Support of Financial Reporting Threshold Modernization Act
Posted September 25, 2018 by CUNA Advocacy

Earlier this week, CUNA wrote to Representative Loudermilk in support of his recently introduced legislation, the Financial Reporting Threshold Modernization Act.   If enacted, this legislation would provide a “much needed and long overdue” modernization of Bank Secrecy Act (BSA) reporting thresholds. 

“In 1970, few ordinary consumer financial transactions exceeded $10,000—the current (and original 1970- designed) trigger for financial institutions to file Currency Transaction Reports (CTRs),” CUNA President/CEO Jim Nussle wrote.

“Nearly half a century later, however, the retail sticker price of even the most basic automobile exceeds $10,000, meaning credit unions engaged in the business of providing cooperative credit vehicle loans to member-owners need to investigate and fulfill burdensome paperwork requirements to inform the government of what they already know to be not suspicious activity—diverting resources from the business of lending and also obscuring actual suspicious financial activity from law enforcement,” he added.

Specifically, Loudermilk’s bill would increase:

  • The CTR threshold to $30,000, up from the current $10,000. CUNA also noted the $30,000 number is “significantly less than the near $70,000 the threshold would be if adjusted for real inflation;”
  • The dollar amount thresholds for filing Suspicious Activity Reports (SARs) to $10,000 (up from $5,000) and to $3,000 (up from $2,000).