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NAFCU Vice President of Legislative Affairs Brad Thaler Wednesday wrote to the House Financial Services Committee prior to today’s hearing “Oversight of the Financial Crimes Enforcement Network.” In the letter, Thaler reiterates NAFCU’s request to modernize and streamline suspicious activity reports (SARs) and records that can better identify financial crimes.

Thaler mentions that the SAR reporting thresholds are outdated, having “remained unchanged for decades.” Due to this issue, in combination with the rapidly increasing inflation rate, NAFCU recommends that FinCEN immediately begin studying the impacts of tying the SAR reporting thresholds to inflation.

“The outdated thresholds cause some SARs to be useless to law enforcement because behavior that was once thought of as suspicious has since become common transaction practice,” added Thaler.

Thaler also adds how these outdated SARs thresholds cause major burdens for credit unions as their members rely on them to assist with all financial matters; and the burden of notifying reporting companies should not lay on their shoulders.

In addition, the letter discusses FinCEN’s previous indication that it views itself as “technology neutral,” regulating the activity of money transmission and not just specific types of transactions – since credit unions continue to abide by BSA/AML rules and regulations and the risks associated with digital assets remain a significant concern.

“As FinCEN and other federal agencies work together on an initial government-wide strategy regarding digital assets regulation and supervision, it is important that FinCEN maintain its technology neutral stance,” stated Thaler.

Read the full letter. NAFCU will continue to work with Congress and FinCEN to make sure credit union concerns are recognized.