WASHINGTON — The Defense Credit Union Council is urging the Treasury Department and Congress to raise decades-old federal transaction-reporting thresholds, arguing the current standards impose unnecessary compliance costs on credit unions without providing corresponding benefits to law enforcement.
In separate letters to Treasury Secretary Scott Bessent and House Financial Services Committee Chairman French Hill (R-AR), DCUC called for modernization of Currency Transaction Report and Suspicious Activity Report requirements under the Bank Secrecy Act.
DCUC said it supports H.R. 1799, the Financial Reporting Threshold Modernization Act, which would raise the general CTR threshold from $10,000 to $30,000 and applicable $5,000 SAR thresholds to $10,000. The legislation also would require the thresholds to be adjusted for inflation every five years.
“Today’s reporting thresholds were established decades ago and no longer reflect the economic environment in which credit unions and their members operate,” DCUC Chief Advocacy Officer Jason Stverak said. “Modernization should reduce low-value compliance work while preserving the information law enforcement needs to identify and disrupt illicit finance.”
Should Have Been Included From the Outset
DCUC said credit unions should be included from the outset in any Treasury or congressional effort to modernize the requirements rather than having to seek relief after new rules have been implemented.
The organization pointed to a Government Accountability Office finding that Treasury established the $10,000 CTR threshold in 1972 and has never adjusted it for inflation. According to DCUC, the GAO calculated that the threshold would have been approximately $72,880 in 2023 if it had kept pace with inflation.
Against that comparison, Stverak said raising the threshold to $30,000 would represent a measured increase rather than a full inflation adjustment.
DCUC also argued that automatically adjusting the thresholds for inflation is important because a one-time increase would eventually be eroded by rising prices, potentially recreating the same compliance problem.
The Defense Council previously endorsed H.R. 1799 in January and again called for higher thresholds, inflation adjustments and clearer reporting requirements in a May letter addressing broader Bank Secrecy Act modernization.
‘Important Context’
Beyond increasing the dollar thresholds, DCUC urged Treasury to consider how a financial institution’s longstanding relationship with a customer or credit union member can be incorporated into risk assessments.
“Verified transaction history, established member relationships, and an institution’s understanding of normal account activity can provide important context,” Stverak said.
DCUC cautioned, however, that the length of a member relationship should be only one factor considered and should not provide an automatic exemption from reporting genuinely suspicious activity.
Coordinated Implementation Urged
DCUC also called for Treasury, the Financial Crimes Enforcement Network, NCUA and other regulators to coordinate implementation of any changes so credit unions do not face inconsistent examination standards.
DCUC cited interagency SAR guidance issued in October 2025 that clarified a transaction at or near the CTR threshold does not by itself require the filing of a SAR when there is no information suggesting an attempt to evade BSA reporting requirements. The guidance also said the BSA does not require institutions to document decisions not to file a SAR under those circumstances, according to DCUC.
“Credit unions should not be encouraged to replace routine CTR activity with defensive SAR filings simply because a transaction happens to fall near a reporting threshold,” Stverak said.
DCUC said consistent examiner training and supervisory guidance will be necessary to ensure any regulatory relief provided through higher thresholds results in actual reductions in compliance burdens.
Request to Simplify Forms
The organization also asked Treasury to consider simplifying reporting forms, eliminating fields that provide limited investigative value and providing clearer instructions for aggregating related transactions.
DCUC urged Treasury not to make changes to CTR and SAR thresholds dependent on completion of every other initiative involving BSA modernization. Instead, the council called for a public implementation roadmap detailing milestones for proposed threshold changes, outstanding Anti-Money Laundering Act reviews and reports, interagency coordination and implementation, as well as identifying changes that would require congressional action.
“DCUC is not seeking a retreat from the fight against illicit finance,” Stverak said. “We support maintaining appropriate reporting safeguards and targeted government-industry information sharing. For defense credit unions, protecting the financial system and supporting military financial readiness are complementary responsibilities.”
