ICBA backs bill to raise CTR, SAR reporting thresholds

ICBA expressed strong support for legislation to raise reporting thresholds for currency transaction reports and suspicious activity reports.

About the Legislation: Introduced by Rep. Barry Loudermilk (R-Ga.), the Financial Reporting Threshold Modernization Act (H.R. 1799) would raise the CTR and SAR thresholds to $30,000 and $10,000, respectively, and index the CTR threshold for inflation every five years.

ICBA Support: In a letter to the bill’s sponsors, ICBA said CTR and SAR filings are a primary source of community bank compliance burden and expense, diverting resources that could be better directed toward community lending. H.R. 1799 follows the recommendations of a recent GAO report required under the Anti-Money Laundering Act of 2020 to reduce the number of unused CTRs filed by community banks by adjusting the Bank Secrecy Act reporting thresholds.

Background: ICBA said current reporting thresholds under the BSA are significantly outdated and capture far more transactions than originally intended, noting that the CTR and SAR thresholds have not been adjusted since 1972 and 1992, respectively.

Past Advocacy: In a 2022 comment letter, ICBA laid out its plan for FinCEN to modernize its BSA framework, urging the agency to raise SAR and CTR thresholds and withdraw bank beneficial ownership collection and verification requirements, among other recommendations.