CUNA Regulatory Comment Call


June 30, 2003

Proposed Currency Transaction Report (CTR) Revision
Foreign Currency Transactions

EXECUTIVE SUMMARY

Comments are due to FinCEN by July 18, 2003. Comments should be sent to: ATTN: PRA Comments " CTR Form, Office of Chief Counsel, Financial Crimes Enforcement Network, Department of the Treasury, P.O. Box 39, Vienna, Virginia 22183. Or you may e-mail comments to regcomments@fincen.treas.gov. Please submit your comments to CUNA by July 15, 2003. Please feel free to fax your responses to CUNA at 202-638-7052; e-mail them to Associate General Counsel Mary Dunn at mdunn@cuna.com or to Senior Regulatory Counsel Catherine Orr at corr@cuna.com ; or mail them to Mary and Catherine in c/o CUNA’s Regulatory Advocacy Department, 601 Pennsylvania Avenue, NW, South Building, Suite 600, Washington, DC 20004-2601. To obtain a copy of the draft CTR form, please contact us or go to CUNA’s website at

http://www.cuna.org/member/download/eguide_bsa_fratt.pdf.

QUESTIONS REGARDING THE PROPOSED CTR REVISIONS

  1. Do you believe the proposed changes to the CTR form would serve to improve the usefulness of the form to law enforcement as well as to NCUA?

    Yes ______ No ______

    Please explain why or why not.













  2. Are there additional/other ways to enhance the quality, utility, and clarity of the information to be collected on the CTR form?

    Yes ______ No ______

    If yes, what are those additional/other ways to improve the information collection?













  3. Do you agree that when foreign currency is involved, financial institutions should utilize the exchange rate as of the day the currency is presented for purposes of filling out a CTR?

    Yes ______ No ______













  4. Other comments?













Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
Mary Mitchell Dunn • SVP & Associate General Counsel • (202) 508-6736 • mdunn@cuna.com
Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 • jbloch@cuna.com
Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 • corr@cuna.com