Removing Barriers Blog

Comments submitted to FinCEN re: SAR requirements
Posted July 28, 2020 by CUNA Advocacy

Yesterday, CUNA wrote to the Financial Crimes Enforcement Network (FinCEN) in support of updating the Paperwork Reduction Act (PRA) requirements for complying with the Bank Secrecy Act (BSA) regulation that requires financial institutions to file Suspicious Activity Reports (SARs) Adjustment to the PRA burden calculation.

CUNA believes this will “lead to greater accuracy in detailing the true cost to a financial institution for filing a SAR,” according to its letter of support.

Specifically, the proposal would expand the annual PRA burden estimate to cover three stages of the SAR production process:

  • The review of cases based on monitoring alerts considered true positives;
  • The documentation of the decision not to turn a case into a SAR; and
  • The SAR filing process, will help more accurately detail the cost to financial institutions for filing SARs.

“Having the most accurate PRA burden calculation for SARs is important as financial institutions expend vast resources filing these reports,” CUNA’s letter reads.

“Furthermore, understanding this complete burden is an important step in determining whether the information gathered from SARs is worth the cost to financial institutions to produce the reports.