On October 22nd the U.S. House passed H.R. 2513, the Corporate Transparency Act of 2019. This legislation addresses the redundancies, unnecessary burdens, and opportunities for efficiencies within the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) statutory framework. And of particular note to credit unions – amended onto the bill was H.R. 2514, the COUNTER Act of 2019, which would index for inflation every five years the Currency Transaction Reporting (CTR) threshold, and further reviews the Suspicious Activity Reporting (SAR) threshold.
Credit unions have been focusing attention with members of Congress on the need to increase the CTR and SAR dollar threshold triggers, which have not been updated since the law was enacted in 1970. The concern is that the lower threshold does nothing to help curb the crime it is intended to prevent, but rather dilutes the focus and creates busywork for the sake of busywork. Credit unions may recall that back in May U.S. Rep. Barry Loudermilk (R-11) from Georgia was instrumental in creating the bipartisan support needed to pursue this relief for financial institutions, and publicly cited the concerns from his discussions with Georgia credit unions in the early debate on the bill. Our thanks to his office, as well as CUNA who prior to the vote on the House Floor wrote to Speaker Pelosi and Leader McCarthy noting credit union support for both pieces of legislation. And while the bill has a long way to go (as it still needs to clear the process in the Senate), this is a positive step for combating crime as well as keeping common-sense regulatory reform for credit unions in play!