WASHINGTON (5/13/08)--The Credit Union National Association (CUNA) is asking credit unions for comments on a regulatory proposal intended to simplify current Customer Transaction Report (CTR) exemption rules for credit unions and other depository institutions. The rule changes were proposed May 6 by the Financial Crimes Enforcement Network (FinCEN) and CUNA requests comments by June 6. They are due to FinCEN by June 23. Bank Secrecy Act (BSA) regulations require that each financial institution, including every credit union, file a CTR of each transaction involving currency of more than $10,000, but exceptions are allowed. One of the major changes proposed by FinCEN to the exemption rule would excuse depository institutions from completing FinCEN Form 110, for certain Phase I members/ customers , now required for all Phase I members/customers. FinCEN proposes to exclude depository institutions, federal, state, or local governments, or entities exercising governmental authority from the requirement. Another FinCEN amendment would abolish the annual review of information supporting the listed Phase I eligible members/ customers. Additionally, FinCEN is proposing to ease its depository institution requirements for Phase II members/customers, which includes businesses that are not listed under Phase I but are eligible for exemption. Under the proposed rule, financial institutions no longer would be required to wait 12 months before designating eligible Phase II customers for exemption. Instead, institutions could institute a risk-based approach to determine how much time to maintain an account before an initial Phase II exemption could be provided to the customer. FinCEN also is considering an alternative proposal that would set a shorter length of time to consider Phase II entities. Other issues on which CUNA asked for guidance dealt with FinCEN’s contemplated changes in such areas as, factors to be considered in conducting a risk-based assessment, and situations where there is a filing of revocation of exemption. Use the resource link below for more information on the CUNA comment call.