WASHINGTON – The Federal Reserve Board and the Financial Crimes Enforcement Network issued an advance notice of proposed rulemaking soliciting public comment on the impact of lowering or eliminating the $3,000 benchmark for documentation of wire transfers.

Credit unions and others have a 60-day window to submit comments on the benefits and burden of lowering or eliminating the threshold. The ANPR also seeks input from the general public on how this possible change might affect their wire transfer practices. NCUA has signed onto a letter with the other federal depository institution regulators suggesting the Fed and FinCEN reconsider lowering the cap because of "the magnitude of the proposed reporting requirement and the associated potential industry burden and costs.

The rule was initially adopted in 1995, so the Fed and FinCEN felt it was appropriate to reassess the amount. Additionally, the Financial Action Task Force-the international anti-money laundering and terrorist financing body-recommended the floor be set no higher than $1,000. The agencies also suggested that technological advances have reduced burdens since 1995.