Many credit unions have not filed any Bank Secrecy Act-mandated Suspicious Activity Reports (SARs)or Currency Transaction Reports (CTRs) for the past two years, Financial Crimes Enforcement Network (FinCEN) Director Jennifer Shasky Calvery told a credit union group on Tuesday.
“Some early research we are looking at suggests that we have a surprisingly larger ... statistically relevant and unusual number of credit unions that over a seven quarter period filed neither a SAR or CTR,” she said at a government relations event sponsored by the National Association of Federal Credit Unions. “There could be problems with the data," she added, but called the number of non-reporters “surprising.”
First of all there are a number of credit unions that do not operate with cash. Or are so small that none of its members of modest means (the ones bankers only want CUs to serve) would never have $10K in cash. So those credit unions would not be filing CTRs. Most people of modest means are not doing suspicious activity - especialy activity that would attract law enforcement attention. Thus Madam Director it makes sense that many credit unions have not filed CTRs in the last two years - if not five, if not ever.
ReplyDeleteThen there's the thousands that ARE a risk.
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