FinCEN recently released feedback regarding the 2009 CTR Exemption Rule which took effect on January 5, 2009. The purpose of this amendment is to simplify the Designation of Exempt Persons (DOEP) process which in turn will reduce the number of CTRs filed. So has this rule assisted in reducing the amount of CTRs filed? Yes—CTRs have declined almost 12% over the 2008 to 2009 time period. The benefits of this rule are:
- Decreased cost and time in preparing and reviewing DOEPs
- Decrease cost and time in preparing CTRs,
- Increased benefits of CTRs by allowing the value of CTRs to surface for law enforcement review
FinCEN used a bifurcated process to analyze the data. The two groups were; Small-Asset-Institution and Large-Asset-Institution. With 82% of the Small-Asset-Institution population being credit unions I would say this category relates to “us.” The report states Small-Asset-Institutions unnecessarily continued to file biennial renewal DOEPs … and unnecessarily continued to file amended DOEPs” (Pg 23 & 24). The word ‘unnecessarily’ makes me wonder if Small-Asset-Institutions really understand the amendment. Perhaps the decline in CTR filings in this group is due to something unrelated to regulations…maybe a poor economy? My point is this; if your credit union is still filing biennial renewal and amended DOEPs maybe you should ask yourself—is it necessary?
Read the entire Fincen report here.