Banking and Finance Law Daily Wrap Up, BANKING OPERATIONS—Financial reporting modernization legislation introduced, (Mar 5, 2025)

By Colleen M. Svelnis, J.D.

The legislation would raise the SAR and currency transaction reporting thresholds. Industry association ICBA sent a letter in support of the bill.

U.S. Representative Barry Loudermilk (R-Ga.) has reintroduced legislation intended to modernize financial reporting and protect consumer privacy. The Financial Reporting Threshold Modernization Act (H.R. 1799) would raise the currency transaction reporting (CTR) and Suspicious Activity Reporting (SAR) thresholds to $30,000 and $10,000 respectively and index the CTR threshold for inflation every five years prospectively. The inclusion of the periodic adjustment for inflation will protect privacy, reduce compliance costs, and realign the threshold with Congressional intent.

Loudermilk issued a statement where he discussed the need for the updated legislation. He stated that when Congress passed the Bank Secrecy Act of 1970, “they did so with the clear intent to monitor significant and unusual financial transactions.” He noted that the $10,000 threshold implemented then has not kept up with inflation and is “grossly outdated and captures millions of commonplace transactions, like used car purchases and small business cash deposits.” He stressed that this must be updated to “meet the realities of the 21st Century.”

H.R.1799, Loudermilk states, would reduce the compliance burden for banks and credit unions, while ensuring law enforcement still has access to this tool when needed. He also expressed his intention that raising the threshold “will enhance customer privacy and allow federal law enforcement and intelligence agencies to focus on the data that really matters.”

Rep. Troy Downing (R-Mont.) also supported the bill, highlighting that in order to protect rural communities, financial regulation should not discriminate against smaller institutions. Downing noting that financial institutions are required to report cash transactions “on an arbitrary basis without adjustment for inflation, resulting in unnecessary compliance burdens for firms, especially community banks.”

ICBA letter. Industry association Independent Community Bankers of America sent a letter in support of the renewed proposed legislation. In addition to Rep. Loudermilk, the ICBA letter was also addressed to Reps. Andy Barr (R-Ky.), Troy Downing (R-Mont.), and Tim Moore (R-N.C.).

ICBA’s letter referenced a report by the Government Accountability Office (GAO) which found the following: law enforcement only accessed 5.4 percent of the 167 million CTRs in the BSA portal filed between 2014 and 2023; if adjusted for inflation, today’s CTR threshold would be more than $72,000; and using an inflation-adjusted threshold would have reduced the number of CTRs filed by at least 90 percent annually since 2014. GAO then recommended reducing the number of unused CTRs by raising the reporting threshold. ICBA noted that H.R. 1799 “would effectively implement this GAO recommendation, relieve counterproductive, community bank regulatory burden, and allow community banks to better serve their customers and communities.”

Companies: Independent Community Bankers of America

LegislativeActivity: BankingOperations BankSecrecyAct GCNNews Privacy