WASHINGTON-Separating domestic and international wire transfers would be "problematic" for smaller financial institutions, including credit unions, CUNA said in a comment letter to the Financial Crimes Enforcement Network. Treasury, through FinCEN has been mandated by Congress to investigate the feasibility of reporting cross border electronic funds transfers in support of efforts to fight money laundering and terrorist financing. "However, mandating that financial institutions must segregate cross border transfers from domestic transfers may be problematic, especially for smaller institutions," CUNA Assistant General Counsel Lily Thomas wrote. "Smaller credit unions typically send and receive wire transfers through a correspondent, which is generally a corporate credit union or larger financial institution. When a transfer is received by a correspondent, the domestic and cross border transfers are not distinguished." Additionally, she pointed out that credit unions would also have to set up new recordkeeping procedures because some credit unions-mostly smaller ones-maintain wire records by account number rather than by date because of frequently requested account information in government subpoenas. "If cross border transfer information would be required to be reported, data processing systems would need to be upgraded to enable credit unions to retrieve the required information," Thomas added.