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Michigan Credit Union League

MCUL Submits Comments to FinCEN on BSA Regulations

In December, the Financial Crimes Enforcement Network (FinCEN) issued a Request for Information to solicit comments on ways to streamline, modernize and enhance Bank Secrecy Act (BSA) regulations.

In response, this week MCUL submitted several comments on behalf of Michigan credit unions, which focused primarily on regulatory relief, such as the raising of the Currency Transaction Report (CTR) threshold and a simplification of the Suspicious Activity Report (SAR) process.

Also included in the comments were calls for increased transparency and for a spirit of collaboration between the agency and the institutions it regulates.

Read MCUL's full comments here.

CUNA also submitted a letter to FinCEN. In it, they noted that Suspicious Activity Report (SAR) and Currency Transaction Reports (CTRs) should be modernized, as they are among the most “burdensome and time consuming” for all BSA/AML programs.

“The burdens created by BSA framework and the AML/CFT regime are significant. These requirements often impose significant compliance cost related to software and staffing, and consume large quantities of staff time, especially where manual processes are involved,” the letter reads. "Given the tremendous expenditure of resources, it is reasonable and appropriate for FinCEN to conduct this review, and future reviews on a regular basis.”

The letter also recommends FinCEN:

  • Issue information on what information from SARs are most useful to law enforcement.
  • SAR and CTR forms should combined into one form and submitted to a single place.
  • Revisit the requirement to file marijuana limited SARs.
  • Update its guidance to clearly and concisely state 314(b) communication can be shared for all suspected financial crimes and BSA violations.
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2022-02-15 00:00:00