November 04, 2020

CUs: How would BSA recordkeeping, travel rule reg changes affect operations?

Reg AlertNAFCU sent members a Regulatory Alert Tuesday detailing the Financial Crimes Enforcement Network's (FinCEN) advanced notice of proposed rulemaking (ANPR) to amend the Bank Secrecy Act's (BSA) recordkeeping and travel rule regulations. NAFCU encourages credit unions to offer feedback on the proposed rule to help inform the association's recommendations to FinCEN.

The ANPR was proposed last month in coordination with the Federal Reserve Board and does not impose any new requirements to retain additional or new information under the recordkeeping and travel rules, other than those resulting from the change to the applicable thresholds.

In the Regulatory Alert, NAFCU highlights the changes that are made by the ANPR and explains how they may impact credit unions, including:

  • a reduction of the recordkeeping and travel rule threshold from $3,000 to $250 for funds transfers and transmittals of funds that begin or end outside the U.S.; and
  • a definition for the meaning of “money” in the recordkeeping and travel rules to apply to domestic and cross-border transaction involving convertible virtual currency.

In addition, NAFCU poses several questions for credit unions to consider when providing feedback on this topic. Comments on the proposed rule are due to NAFCU Nov. 24; comments are due to FinCEN Nov. 27.

For more on the proposed changes, including an in-depth section-by-section analysis, view the Regulatory Alertsubscribe to receive Regulatory Alerts.