ARLINGTON, Va. — The Seasoned Customer CTR Exemption Act of 2007 (H.R. 323) would provide credit unions and other financial institutions with important regulatory relief, NAFCU said in a letter President/CEO Fred Becker wrote last week to the Senate Banking Committee leaders.
NAFCU's letter, addressed to Chairman Chris Dodd (D-Conn.) and Ranking Member Richard Shelby (R-Ala.) and copied to all committee members, pushed for the committee to consider the legislation that would "provide important regulatory relief to credit unions and other financial institutions."
"By the point someone qualifies for a 'seasoned' customer (member) status, they've passed through the Customer Identification Program and Customer Due Diligence process, and the credit union has had a good amount of time–likely 12 months–to review his or her (or its) transactions. CTRs would have to be filed during the non-exempt period, until the customer (member) qualifies. Even after that point, financial institutions would still be under a requirement to file a Suspicious Activity Report (SAR) whenever any transaction deemed to be suspicious under BSA regulations," Becker pointed out.
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Law enforcement concerns should be eased by the fact that the Federal Financial Institutions Examination Council's Bank Secrecy Act/Anti-Money Laundering Examination Manual has clarified requirements and credit unions and other financial institutions have responded. "In addition, credit unions across the country are implementing detailed due diligence programs that will allow them to anticipate the transactions of their members, which will in turn allow them to uncover suspicious activity that falls outside of the normal transaction pattern of their members," Becker wrote.
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