Incomplete Reporting

Register now

The National Credit Union Administration is expressing concerns over the quality of Suspicious Activity Reports and Currency Transaction Reports.

The filings are designed to provide law enforcement with lead information that may help the Financial Crimes Enforcement Network (FinCen) to identify illegal funds. NCUA said that while CUs have been filing SARs and CTRs in a timely manner, there are data quality concerns with some of the SARs and CTRs filed by credit unions.

"Based on discussion with FinCEN," NCUA said most quality problems of SAR filing by credit unions include reporting to the wrong regulator. "All credit unions should report to NCUA as the primary federal regulator, regardless of insurance status," NCUA said.

In other cases credit unions filing reports have been leaving blank the space for the "Employer Identification Number" or don't type a "brief narrative description on part V" of the suspicious activity report. "FinCen doesn't receive any attached documents," the NCUA said. Summarizing the information is the best way to help law enforcement, according to FinCen.

In addition, credit unions must assure that the form they are using is correct by checking into a box on the upper-right-hand corner of the first page. "All credit unions must file SAR form TD F 90-22.47 (Treasury), also called 2362 (NCUA).


The NCUA said that in the case of Currency Transaction Reports, the filings also show CUs reporting to wrong regulators instead of NCUA and missing employee information numbers, also known in the forms as EIN.

"Credit unions should always be able to describe what kind of activity occurred," it said. Sometimes the type of activity is not completed, it said.

The page form should have the number CTR form 104 in the top left hand corner.

The statement from the NCUA Office of Examination and Insurance was sent to The Credit Union Journal by the organization's spokesperson, Cherie Umbel.

According to a study by the Treasury Department's Office of the Inspector General, SAR reports filed by banks often go ignored because information needed to follow up with an investigation is incomplete, The American Banker said.

The newspaper, which is an affiliate of The Credit Union Journal, reported that the volume of SAR filings by banks in recent months has exploded as a consequence of large fines imposed on AmSouth Bancorp and Riggs National Corp.

For reprint and licensing requests for this article, click here.