WASHINGTON–The Financial Crimes Enforcement Network (FinCEN) and Federal Reserve has withdrawn a proposaloriginally made in2020 that would have lowered the Bank Secrecy Act (BSA) Recordkeeping Rule and Travel Rule thresholds to $250 (down from the current $3,000 threshold) for international funds transfers.
America’s Credit Unions’ noted that CUNA and NAFCU—which later merged to form the group– opposed the 2020 proposal, “arguing that the lower threshold would significantly increase compliance costs and burdens without sufficient evidence of additional benefits to law enforcement.”
America’s Credit Unions called the withdrawal a “positive and consistent” move that aligns with its “longstanding advocacy for reducing unnecessary BSA compliance burdens.
“In the published withdrawal, both agencies acknowledged many of the concerns raised by commenters, including the potential impact on smaller financial institutions, which the legacy organizations specifically flagged,” the trade group added.
General Support for FASB Proposal
Separately, the Financial Accounting Standards Board (FASB) has proposed updates to recapture in the measurement of residential mortgage servicing rights (MSRs), and America’s Credit Unions has filed comments that is noted generally support the proposal, which would require entities to incorporate the value of recapture into residential MSR fair value.
In its letter, America’s Credit Unions said it offered recommendations targeted implementation guidance and illustrative examples to:
- Clarify the scope and definition of residential mortgage loans and how recapture may be reflected in valuation models;
- Prevent double counting of recapture value and distinguish permissible recapture assumptions from benefits associated with future originations or other separately recognized assets; and
- Address transition, auditability, and interest rate lock commitments.
America’s Credit Unions also recommends FASB provide at least a one-year implementation period.
The letter can be found here.
