Currency Transaction Report Threshold: By: Colin Carr, Legislative Director, Congressman Barry Loudermilk
Currency transaction report threshold: On May 8-9, Congressman Loudermilk took an active role in the Financial Services Committee’s markup of eight pieces of legislation, including a bill to reform the Bank Secrecy Act (BSA) and anti-money laundering (AML) compliance regime. As you may know, he has sponsored a bill that would increase the BSA’s currency transaction report (CTR) threshold from $10,000 to $30,000, increase the suspicious activity report (SAR) threshold from $5,000 to $10,000 for depository institutions, and increase the SAR threshold from $2,000 to $3,000 for money services businesses.
The original BSA/ AML reform bill that was considered in the markup did not include any provisions to address these thresholds, so Congressman Loudermilk worked with Members from both parties to find common ground on the issue. It became clear that the SAR threshold is much more of a sticking point than the CTR threshold, so he proposed an amendment that would have phased in an increase to the CTR threshold for depository institutions over time from $10,000 to $20,000 and then from $20,000 to $30,000. The amendment also proposed a Government Accountability Office (GAO) study to analyze the usefulness of CTRs and whether the threshold should be raised, and a similar study on SARs.
Most committee members from the majority have long maintained that they will not support any threshold increases, so Congressman Loudermilk negotiated a compromise and withdrew his amendment. The compromise would (1) index the CTR threshold to inflation for depository institutions starting at the current threshold of $10,000, (2) require the GAO to study how to improve the usefulness of CTRs which Congressman Loudermilk proposed in his original amendment, and (3) require FinCEN to conduct a study on reducing SAR reporting burden, including the possibility of a shorter form SAR for known or trusted customers. The BSA/ AML reform bill ultimately passed the committee with these provisions included by a unanimous vote of 55-0. This is significantly less than what Congressman Loudermilk would like to do on the thresholds, and he will continue to find ways to advance his bill, but he views this compromise as a small step in the right direction. You can listen to his statements at the markup here and here.
EVP, Chief of Staff, Government & Regulatory Relations
Government and Regulatory Relations Associate
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