WASHINGTON -- CUNA met with the Government Accountability Officerecently to explain credit unions' particular problems withCurrency Transaction Reports as the agency produces a study on itfor Congress.

The GAO is performing the research as directed under theregulatory relief law enacted last year. The House has alreadypassed legislation this year to exempt financial institutions fromhaving to file CTRs on "seasoned customers," as introduced byFinancial Services Committee Ranking Member Spencer Bachus(R-Ala.).

According to CUNA Deputy General Counsel and Senior VicePresident Mary Dunn, CUNA staff invited GAO researchers to meet atCUNA's Washington, D.C. headquarters along with State EmployeesCredit Union (N.C.) Chief Compliance and Risk Manager Tom Lawlerand Maryland & D.C. Credit Union Association President/CEO MikeBeall to discuss their issues.

Dunn explained, "By and large credit unions are not [using theexemption process] because it's not really that helpful." GAO isparticularly looking into the exemption process, as well as thecompliance burden on smaller institutions and costs, she said. Fromcredit unions' perspective, she said, it is easier to file CTRs asneeded rather than deal with the exemption process.

Training employees is also easier when there is a flat rule offiling over $10,000, Dunn added.

The credit union representatives told GAO that the reportingthreshold should be adjusted; knowing how law enforcement uses CTRswould be beneficial; filing based on the risk of the transactionshould be considered; and small and mid-sized credit unions areparticularly burdened with Bank Secrecy Act-related compliance.They also explained that several credit union staff members reviewCTRs to ensure everything is correct, which is an added burden.

She expects the GAO report to be submitted to Congress earlynext year.

CUNA has offered to coordinate additional meetings between GAOand credit unions. CUNA Chairman Allan Kemp McMorris has requestedits Examinations and Supervision Subcommittee to name a task forceto address a range of BSA-related issues. [email protected]