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A proposed rule on the reporting of cross-border electronic transmittals of funds wouldn't have much impact on credit unions, but NAFCU questions whether it's really useful or wise given the vast amount of information already reported under federal anti-money laundering and anti-terrorism rules.

The Financial Crimes Enforcement Network has proposed that depository institutions be required to report all cross-border electronic transmittals of funds and to file an annual report listing the taxpayer identification number for each account holder who sent or received funds in this manner during the calendar year.

The proposal's "first in/last out" reporting method will narrow the rule's application in practice, and in most cases the reporting would be done by third parties (such as CHIP or SWIFT). As for TIN reports, this is not expected to generate significant new regulatory burden.

Even so, NAFCU is concerned about the rule itself, and it told FinCEN Wednesday that it is skeptical of the benefit of this new reporting; it questions the utility given the amount of data FinCEN already receives via suspicious activity reports and currency transaction reports; and it has concerns about the "obvious data security issues" involved in the transmission and storage of so much data, and sensitive data at that.

Dillon Shea, NAFCU's associate director of regulatory affairs, said it might be more appropriate to request transmittal and TIN data as needed and that FinCEN consider the burdens – despite the expected, limited impact on credit unions – alongside the utility of such reporting.

"Finally, as the agency is obviously aware, safely and securely transmitting and storing this massive amount of data is a considerable undertaking," Shea continued. He said that, as FinCEN moves forward, it take steps not only to protect against third-party actors but to ensure the system "is not compromised from within."