Compliance: FinCEN seeks comments on proposed CTR changes

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February 8 2016

To remedy perceived limitations of the Currency Transaction Report (CTR), the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) is seeking comments on potential changes to the form. Comments are due by April 4.

According to FinCEN, this is primarily due to the fact that, since the current form was published in March 2011, the current report is
not configured to allow for alternative reporting models that have developed since then.

CUNA’s BSA working group sent a number of ideas for improvements to FinCEN’s BSA advisory group last fall, requesting form simplifications, and an increase in in the CTR threshold to $20,000 from the current $10,000.

The working group noted that $20,000 in 2015 money is lower than the rate of inflation since 1986 when the $10,000 threshold was originally issued.