WASHINGTON–The Treasury Department held roundtable to discuss potential updates to its SAR and CTR thresholds, neither of which has been updated since introduction in 1972.
America’s Credit Unions was among the organizations who had a representative present during the event.
It is estimated that approximately 4.6 million Suspicious Activity Reports were filed during 2024, while the Financial Crimes Enforcement Network (FinCEN) reported approximately 20.5 million Cash Transaction Reports were riled during the same year. Treasury has indicated interest in making changes, including to the threshold reporting requirements.
Currently, credit unions and other financial institutions are required to report within one business day after a consumer transaction of more than $10,000. SARs are filed with FinCEN if a financial institution suspects a transaction of more than $5,000 is related to fraud, money laundering, or other illegal activities.
America’s Credit Unions Head of Compliance Marilyn Barker and Regulatory Advocacy Senior Counsel Luke Martone took part in Treasury discussions, with the trade group reporting that representatives from the FBI, DEA, IRS and Department of Justice were also present.
Push for Increased Thresholds
According to America’s Credit Unions, Barker and Martone told the meeting that modernizing CTRs and SARs would help shift credit union resources toward serving members and communities while continuing to protect against fraud.
Previously, both America’s Credit Unions and the state leagues have expressed support for raising the threshold to $30,000 and for new rules that would also include continuing adjustments for inflation every five years.
America’s Credit Unions has also called on FinCEN to raise the SAR threshold to $10,000.
‘Important to be at Table’
“We highlighted how outdated requirements, and rigid reporting thresholds create an outsized burden for credit unions with limited compliance staff, and urged Treasury to support raising reporting thresholds and streamlining the forms to make them more efficient, targeted, and effective,” said Martone in a statement.
“Having a seat at the table is critical to ensuring credit union voices are heard on issues that directly impact our ability to serve members,” Martone continued. “Credit unions fully support law enforcement, and modernizing these requirements will allow credit unions to devote more resources to member service and community investment.”
