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NAFCU President and CEO Dan Berger and other senior staff today will meet with Financial Crimes Enforcement Network (FinCEN) Acting Director Jamal El-Hindi for an update on the agency's priorities and to discuss credit union concerns with suspicious activity report (SAR) filings, among other topics.

Along with Berger, NAFCU Executive Vice President of Government Affairs and General Counsel Carrie Hunt, Vice President of Regulatory Compliance Brandy Bruyere, Director of Regulatory Affairs Alexander Monterrubio and Senior Regulatory Affairs Counsel Michael Emancipator will attend the meeting.

NAFCU has previously raised concerns about the regulatory burden presented by FinCEN's rules on collecting SARs. Under the Bank Secrecy Act (BSA), financial institutions are required to submit SARs for suspicious transactions involving $5,000 or more. NAFCU has urged that this threshold be adjusted (it hasn't been changed since 1996) and for FinCEN to provide a more realistic estimate of the time it takes smaller institutions to collect SAR information.

The association has also urged FinCEN to develop simplified SAR "notice filings" to speed up the information collection process and minimize the regulatory burden for smaller institutions.

Today's meeting is also expected to address the currency transaction reporting process. NAFCU has asked FinCEN to further streamline the process that credit unions use to report these transactions and to lower the batch reporting minimum.

Other industry ideas related to BSA/anti-money laundering requirements and interagency collaboration will also be addressed today.