ABA Challenges FinCEN Analysis of Proposed CTR Changes

In a comment letter today, ABA criticized the Financial Crimes Enforcement Network’s proposed revisions to the Bank Secrecy Act Currency Transaction Report form. The association argued that the FinCEN proposal does not account for the significant operational and recordkeeping changes that banks will need to implement in order to use the revised form.

The proposed revisions include a new section to capture additional information on the entity filing the CTR; a new requirement that the filer list the amount of funds transacted at each location reported on the form; and a revised definition of “teller.”

ABA pointed out that FinCEN’s estimate of the burden imposed on banks by these revisions did not account for the time or expense required to install and test an upgraded and customized software system, train staff on the new system, or update the bank’s training materials, nor did it show the need for the new information that would be collected by the revised CTR form. ABA urged FinCEN to conduct a more thorough assessment of the burden imposed by the proposed revisions and the need for each revision. For more information, contact ABA’s Rob Rowe or Jonathan Thessin.


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