On Monday, CUNA wrote to the Financial Crimes Enforcement Network (FinCEN) in response to the notice and request for comment regarding renewal of information collection relating to the currency transaction report (CTR) requirements.
We support FinCEN updating the Paperwork Reduction Act (PRA) burden estimates from
complying with the Bank Secrecy Act (BSA) regulation that requires financial institutions to
report transactions in currency of more than $10,000 using FinCEN Report 112, the CTR
report. Adjustment to the PRA burden calculation will lead to greater accuracy in detailing the
true cost to a financial institution for filing a CTR.
We agree that the two additions to the PRA burden calculation are relevant in determining the
entire cost for filing CTRs. The cost to obtain data required by the report that the filer does not
need for its own bookkeeping, and maintaining, updating, and upgrading the technological
infrastructure required to file and store the report are a necessary addition to the PRA
calculation. These costs are critical in determining the true costs for filing CTRs by financial
institutions. Having the most accurate PRA burden calculation for CTRs is important as
financial institutions expend vast resources filing these reports, and understanding this
complete burden is an important step in determining whether the information gathered from
CTRs is worth the cost to financial institutions to produce the reports.