WASHINGTON -- CUNA met with the Government Accountability Office recently to explain credit unions' particular problems with Currency Transaction Reports as the agency produces a study on it for Congress.
The GAO is performing the research as directed under the regulatory relief law enacted last year. The House has already passed legislation this year to exempt financial institutions from having to file CTRs on "seasoned customers," as introduced by Financial Services Committee Ranking Member Spencer Bachus (R-Ala.).
According to CUNA Deputy General Counsel and Senior Vice President Mary Dunn, CUNA staff invited GAO researchers to meet at CUNA's Washington, D.C. headquarters along with State Employees Credit Union (N.C.) Chief Compliance and Risk Manager Tom Lawler and Maryland & D.C. Credit Union Association President/CEO Mike Beall to discuss their issues.
Dunn explained, "By and large credit unions are not [using the exemption process] because it's not really that helpful." GAO is particularly looking into the exemption process, as well as the compliance burden on smaller institutions and costs, she said. From credit unions' perspective, she said, it is easier to file CTRs as needed rather than deal with the exemption process.
Training employees is also easier when there is a flat rule of filing over $10,000, Dunn added.
The credit union representatives told GAO that the reporting threshold should be adjusted; knowing how law enforcement uses CTRs would be beneficial; filing based on the risk of the transaction should be considered; and small and mid-sized credit unions are particularly burdened with Bank Secrecy Act-related compliance. They also explained that several credit union staff members review CTRs to ensure everything is correct, which is an added burden.
She expects the GAO report to be submitted to Congress early next year.
CUNA has offered to coordinate additional meetings between GAO and credit unions. CUNA Chairman Allan Kemp McMorris has requested its Examinations and Supervision Subcommittee to name a task force to address a range of BSA-related issues. --firstname.lastname@example.org