WASHINGTON — The burden of lowering the Currency Transaction Reporting threshold from the current $3,000 level far outweighs any law enforcement benefits and could actually hamper investigations with information overload, two national credit union trade associations wrote last week in individual comment letters to the Federal Reserve.

"Although reducing or eliminating the $3,000 threshold may not substantially impact the price and types of funds transfer services that are offered, credit unions are currently struggling under the burden of complying with the ever increasing requirements posed by the Bank Secrecy Act (BSA) and anti-money laundering (AML) rules, and reducing or eliminating the current $3,000 threshold will further increase this burden," CUNA Senior Assistant General Counsel Jeff Bloch wrote. "We believe law enforcement already has a wealth of information with regard to wire funds transfers. Before new burdens are imposed, credit unions want to be assured that the current information is being reviewed and analyzed to the extent possible and that any new requirements will prove useful to law enforcement, while minimizing the additional burdens on credit unions and others in the financial services industry." To illustrate the point, CUNA said a quick sampling of credit unions determined that approximately half of wire transfers at some credit unions are under $3,000.

This significant increase in the volume of data reported would not necessarily be a positive, NAFCU pointed out in its comment letter. According to NAFCU President and CEO Fred Becker, "This increase in data volume could potentially negate any law enforcement benefits that might be derived from a lower threshold. More is not necessarily better. Indeed, the tremendous growth in defensive [suspicious activity report] filings over the last few years has demonstrated that a problematic 'needle in a haystack' effect may result from expanded reporting requirements."