A recent estimate by the Financial Crimes Enforcement Network of the total cost to file currency transaction reports “significantly underestimates” the burden faced by financial institutions, ABA said in a letter to the agency today. FinCEN estimated the total annual cost to be just more than $54 million.
While ABA generally supported the effort to document CTR costs, the association raised concerns that FinCEN’s estimate omits several key steps involved with CTR processing, including determining whether a CTR must be filed, and makes certain incorrect assumptions about the role of automation in CTR filing. It also fails to incorporate expenses and burdens associated with audit, quality control and error resolution and does not provide a clear, quantitative picture of whether the benefits of CTR filings counterbalance the costs, ABA said.
The association urged FinCEN—which has also sought comment on its methodology for calculating Suspicious Activity Report burden—to continue its work to understand the costs of these filings, ABA called for greater transparency regarding CTR data, noting that “in the long run, greater transparency would help the industry and FinCEN focus better on the costs and benefits of the CTR process.”