The Financial Crimes Enforcement Network underestimates the amount of time and resources community banks dedicate to reporting suspicious activity, ICBA told the agency.

Details: In a comment letter and joint letter with other financial industry groups, ICBA said FinCEN’s estimate that each suspicious activity report, or SAR, takes roughly 1.98 hours to file is grossly undervalued.

ICBA Recommendations: In its comments, ICBA:

  • Urged FinCEN to take a comprehensive approach to calculating all the factors that determine the amount of time it takes to process a SAR.

  • Reiterated its support for increasing the SAR reporting threshold to $10,000.

  • Noted that SAR filings are part of a cumbersome and overly burdensome regulatory environment that hampers community banks’ ability to serve their customers and communities.