ARLINGTON, Va. — NAFCU has written the Office of Management and Budget to comment on NCUA's submission of an information collection request.
NCUA's regulations require credit unions to adopt a written program to ensure continued compliance with currency recordkeeping and reporting requirements under the Bank Secrecy Act. NAFCU's letter explained that the request for collection of information is to allow NCUA to determine whether credit unions have established a program reasonably designed to assure and monitor BSA compliance.
"While NAFCU fully supports the intent and spirit of the BSA law and regulations, we are concerned that the growing reliance on financial institutions to help prevent and detect money-laundering, terrorist financing, and illicit activity is becoming increasingly costly and burdensome to credit unions," NAFCU President/CEO Fred Becker wrote. "BSA compliance consistently remains a top compliance concern among NAFCU member credit unions. Thus, NAFCU strongly believes that the agency should carefully contemplate the burden involved with BSA compliance. Toward that end, NAFCU suggests that NCUA has underestimated the burden hours involved in a credit union's administration of its BSA program."
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Specifically, he pointed out that NCUA estimated that it takes just three hours to review and revise an existing program and the agency estimated seven hours for an entirely new BSA program at a new credit union, according to NAFCU's letter. NAFCU called the estimates "overly conservative and may be a miscalculation of the amount of burden hours involved in effective compliance." Becker stated that personnel training for BSA alone could take well over three hours.
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