DCUC Presses Treasury, Congress To Raise CTR, SAR Thresholds
By CU Today Staff —
WASHINGTON--The Defense Credit Union Council is urging the U.S. Department of the Treasury and Congress to modernize outdated Currency Transaction Report (CTR) and Suspicious Activity Report (SAR) thresholds, reduce unnecessary compliance burdens, and preserve the reporting tools that provide meaningful value to law enforcement.
In separate letters to U.S. Treasury Secretary Scott Bessent and House Financial Services Committee Chairman French Hill, DCUC called for prompt action to update Bank Secrecy Act (BSA) reporting thresholds and ensure credit unions are included in modernization efforts alongside other financial institutions.
DCUC thanked Hill and the Committee for advancing H.R. 1799, the Financial Reporting Threshold Modernization Act, which would raise the general CTR threshold from $10,000 to $30,000, increase applicable $5,000 SAR thresholds to $10,000, and provide for inflation adjustments every five years. DCUC noted that the Congressional Budget Office has similarly described H.R. 1799 as legislation that would update these thresholds and adjust them for inflation every five years.
“Today’s reporting thresholds were established decades ago and no longer reflect the economic environment in which credit unions and their members operate,” says Jason Stverak, DCUC chief advocacy officer. “Modernization should reduce low-value compliance work while preserving the information law enforcement needs to identify and disrupt illicit finance. Credit unions should be included in that effort from the beginning, not asked to seek relief after new rules are already in place.”
DCUC said it has consistently engaged on this issue, including its January 21 letter endorsing H.R. 1799 and its May 19 letter on Bank Secrecy Act modernization calling for updated thresholds, inflation adjustments and clearer reporting requirements.
“The need for modernization is underscored by the age of the current CTR threshold,” explained Stverak. “The Government Accountability Office has reported that Treasury established the $10,000 threshold in 1972 and has never adjusted it for inflation. GAO calculated that the inflation-adjusted equivalent would have been approximately $72,880 in 2023. Against that benchmark, DCUC views a $30,000 threshold as a measured modernization rather than a full inflation adjustment.”
“Periodic inflation adjustments are especially important,” Stverak wrote. “A one-time increase would provide relief today but allow the same problem to recur as prices rise. Congress should establish a durable framework rather than require institutions to return repeatedly for correction of thresholds that have again become outdated.”
DCUC also requested Treasury examine how longstanding customer relationships can inform risk-based treatment.
“Verified transaction history, established member relationships, and an institution’s understanding of normal account activity can provide important context,” Stverak said. “Relationship length should be one factor in risk assessment, however, rather than an automatic exemption or substitute for identifying genuinely suspicious activity.”
DCUC requested that Treasury, FinCEN, NCUA and other regulators coordinate implementation so threshold modernization is not undermined by inconsistent examination expectations. DCUC also pointed to the October 2025 interagency SAR FAQs, which clarified that a transaction at or near the CTR threshold does not, by itself, require a SAR when there is no information indicating an effort to evade BSA reporting requirements, and that the BSA does not require documentation of a decision not to file a SAR in such circumstances.
“Regulatory relief should translate into supervisory practice. Credit unions should not be encouraged to replace routine CTR activity with defensive SAR filings simply because a transaction happens to fall near a reporting threshold. Clear guidance, coordinated examiner training, and consistent expectations will be essential to making modernization work as intended,” said Stverak.
DCUC’s letter requested Treasury pair threshold updates with broader improvements to the reporting process, including simpler forms, removal of fields that provide limited investigative value, and clearer instructions for aggregating related transactions. The goal, DCUC said, should be to preserve reporting that helps law enforcement while reducing confusion and avoidable administrative work.
DCUC also encouraged Treasury to continue moving forward with threshold modernization without making that relief contingent on completion of every other BSA modernization initiative. In its letter, the Council requested a public implementation roadmap identifying milestones for threshold proposals, outstanding Anti-Money Laundering Act reviews and reports, interagency coordination, and implementation, while identifying any statutory changes that may require congressional action.
“DCUC is not seeking a retreat from the fight against illicit finance,” Stverak wrote. “We support maintaining appropriate reporting safeguards and targeted government-industry information sharing. For defense credit unions, protecting the financial system and supporting military financial readiness are complementary responsibilities.”
Originally reported by CU Today.