WASHINGTON (8/9/11)--The National Credit Union Administration (NCUA) should avoid broad-based regulatory requirements in favor of more targeted actions and should refrain from adding to the burden caused by current credit union regulatory requirements, the Credit Union National Association (CUNA) said in a comment letter. The agency should add new regulations or expand existing regulations “only if there is a well-documented and compelling need to do so,” CUNA added. The comment letter, in response to the NCUA’s 2011 regulatory review, noted that “the cumulative regulatory burden is at an all-time high” due to the activities of the NCUA and Dodd-Frank Act regulations. CUNA’s letter focused on portions of the regulatory review addressing security programs, Bank Secrecy Act (BSA) compliance, and crime reporting, as well as requests for agency action. In the letter, CUNA specifically urged the NCUA to minimize BSA-related compliance burdens by encouraging regulators and legislators to help “minimize the costs and problems institutions encounter to meet BSA requirements and to satisfy examiners.” CUNA also suggested some specific BSA changes that would take Congressional action, such as increasing the dollar threshold for filing currency transaction reports to $20,000 from $10,000. CUNA also suggested increasing the threshold for filing Suspicious Activity Reports to $5,000 and at least doubling triggers for reporting wire transfers and money laundering activities. Credit unions are concerned that some of the work of the NCUA’s Office of Consumer Protection could overlap with the priorities of the Consumer Financial Protection Bureau, CUNA added. The NCUA should also work with the U.S. Treasury Department's Financial Crimes Enforcement Network (FinCEN) to minimize areas where NCUA and FinCEN regulations overlap. CUNA said that it would discuss the office with the NCUA soon. CUNA said it plans to comment on other 2011 NCUA regulatory review items later. The NCUA has also targeted rules addressing records preservation programs, appendices-record retention guidelines, catastrophic-act preparedness guidelines, and post-employment restrictions for some NCUA examiners during its 2011 regulatory review. The NCUA reviews its full regulatory catalogue every three years, and schedules reviews of portions of its regulations on a rotating basis. For the CUNA letter, use the resource link.