A Financial Crimes Enforcement Network proposal to renew without change its information collection requirements for currency transaction reports, or CTRs, severely underestimates the time and money banks must expend to meet the nearly 80-year-old requirement, ABA said today in a letter to the agency. The association instead urged the agency to first survey banks and use that data to revise the requirements.
Banks are required by regulation to file CTRs on most fiat currency transactions of more than $10,000. However, after 80 years, $10,000 is no longer an unusually large transaction—adjusted for inflation, the amount would be nearly $170,000 today, ABA said. The association pointed to a March survey of member banks that found that more than a quarter of respondents spent between 25% and 50% of all their Bank Secrecy Act compliance costs on CTR filings.
“Those are resources that cannot be devoted to suspicious activity,” ABA said. “But because having accurate data on CTR burden is essential to policy discussions regarding ways to promote the efficiency and effectiveness of BSA and anti-money laundering compliance, we urge FinCEN to conduct a comprehensive survey of banks in order to revise its estimate and to inform long overdue policy discussions about the need to modernize the CTR rules.”
