Reporting like it’s 1972.

Every day, credit unions serve their members and protect their money.

While many regulations aim to provide a vital safety net, outdated and overburdensome rules do very little to stop crime while uselessly consuming vast amounts of staff time – time credit unions could be spending on helping their members build financial security and achieve the American dream.

Look no further than the reports credit unions must file for cash transactions and suspicious activity: Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs).

Under the Bank Secrecy Act, which is the foundational framework for U.S. anti-money laundering enforcement, financial institutions must file a CTR for every cash transaction of $10,000 or more. If a credit union suspects a member is intentionally breaking up a transaction to evade that limit, it must also file a SAR.

While Congress created these laws to catch illicit financial flows, the system has a glaring structural flaw: the $10,000 threshold. It was enacted in 1972 and has never been updated. If pegged to inflation, that $10,000 benchmark would stand around $80,000 today.

Instead of targeting illicit transfers in money laundering schemes, the current CTR threshold sweeps up routine business and personal transactions. For instance: imagine selling a used car on the private market for $12,000 in cash. In theory, if you are able to break up the deposit, the credit union must file a SAR for potential structuring. If you deposit it all at once, the credit union must file a CTR.

It is a lose-lose dynamic for credit unions because regardless of which choice an ordinary consumer makes to deposit legitimate cash, the transaction is automatically treated with suspicion and creates burdens for both the consumer and the financial institution including verification hurdles and transaction delays. Americans today work with larger nominal dollar figures than they did half a century ago. And still, credit unions are forced to process compliance paperwork based on a standard set the year Elton John released “Rocket Man.”

The operational toll on community institutions is severe. According to our latest survey of member credit unions, the median credit union files more than 1,000 reports (both CTRs and SARs) each year. The vast majority are CTRs, which the Financial Crimes Enforcement Network (FinCEN) estimates take just eight minutes to complete. In reality, our survey reveals they take an average of 20 minutes – more than double FinCEN’s projection.

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Further, the median credit union in our survey spends over 730 hours per year filing CTRs and SARs. For an institution open six days a week, that equals roughly 2.5 hours every single business day dedicated purely to filing paperwork.

And how often does law enforcement follow up on those 1,000-plus filings and 730 hours of labor? Two per year, on average.

A 2024 Government Accountability Office report underscored this disconnect, noting that indexing the threshold to inflation from 1972 would have reduced the total volume of reports filed nationwide by 90% annually. For the median credit union, that represents cutting wasted compliance time from 730 hours down to 73.

The $10,000 CTR threshold is long overdue for a meaningful increase. America’s Credit Unions is advocating for Congress to raise the CTR threshold to at least $30,000 and index it to inflation moving forward, and doubling the SARs threshold from $5,000 to $10,000.

Modernizing these limits strikes the right balance: it ensures law enforcement receives actionable intelligence on genuine financial crimes while eliminating the automated false-flagging of standard transactions conducted by everyday Americans. Outdated reporting thresholds drain vital resources from member-owned institutions. It is time for Congress to update the Bank Secrecy Act thresholds so credit unions can redirect their energy toward expanding access, lowering costs, and serving their communities.