NCUA has issued a regulatory alert to red-flag recent guidance by the Financial Crimes Enforcement Network (FinCEN) on determining account holders' eligibility for exemption from Currency Transaction Report (CTR) requirements. NCUA issued the alert last month reminding credit unions that under the Bank Secrecy Act (BSA) financial institutions must file a CTR on any transaction in currency of more than $10,000. BSA rules do allow exemptions for certain members, or customers, and FinCEN issued the following guidance late last year on a rule that was actually effective Jan. 5, 2009. In that rule, the NCUA alert noted, FinCEN made the following changes to the previous CTR exemption system:
- Eliminated the designation and annual review requirement for most credit unions
- Decreased the definition of "frequent reportable transactions" from eight to five transactions
- Decreased the waiting time for CTR exemption eligibility from twelve months to two months; and
- Eliminated the CTR exemption biennial renewal requirement.
The FinCEN guidance (FIN-2009-G003) also addresses the most frequently asked questions regarding the CTR exemption. For details, see NCUA regulatory alert on the CTR rules.
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