Agency Information Collection Activities; Proposed Renewal; Comment Request; Renewal Without Change of the Bank Secrecy Act Reports of Transactions in Currency Regulations at 31 CFR 1010.310 Through 1010.314, 31 CFR 1021.311, and 31 CFR 1021.313, and FinCEN Report 112-Currency Transaction Report
| Citation | 85 FR 29022 |
| Record Number | 2020-10310 |
| Published date | 14 May 2020 |
| Section | Notices |
| Court | Financial Crimes Enforcement Network |
Federal Register, Volume 85 Issue 94 (Thursday, May 14, 2020)
[Federal Register Volume 85, Number 94 (Thursday, May 14, 2020)]
[Notices]
[Pages 29022-29030]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-10310]
[[Page 29022]]
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DEPARTMENT OF THE TREASURY
Financial Crimes Enforcement Network
Agency Information Collection Activities; Proposed Renewal;
Comment Request; Renewal Without Change of the Bank Secrecy Act Reports
of Transactions in Currency Regulations at 31 CFR 1010.310 Through
1010.314, 31 CFR 1021.311, and 31 CFR 1021.313, and FinCEN Report 112--
Currency Transaction Report
AGENCY: Financial Crimes Enforcement Network (FinCEN), Treasury.
ACTION: Notice and request for comments.
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SUMMARY: As part of its continuing effort to reduce paperwork and
respondent burden, FinCEN invites comments on the proposed renewal,
without change, of currently approved information collections relating
to reports of transactions in currency. Under Bank Secrecy Act
regulations, financial institutions are required to report transactions
in currency of more than $10,000 using FinCEN Report 112 (the currency
transaction report, or CTR). Although no changes are proposed to the
information collections themselves, this request for comments covers a
proposed updated burden estimate for the information collection. This
request for comments is made pursuant to the Paperwork Reduction Act of
1995 (PRA).
DATES: Written comments are welcome, and must be received on or before
July 13, 2020.
ADDRESSES: Comments may be submitted by any of the following methods:
Federal E-rulemaking Portal: http://www.regulations.gov.
Follow the instructions for submitting comments. Refer to Docket Number
FINCEN-2020-0003 and the specific Office of Management and Budget (OMB)
control numbers 1506-0004, 1506-0005, and 1506-0064.
Mail: Policy Division, Financial Crimes Enforcement
Network, P.O. Box 39, Vienna, VA 22183. Refer to Docket Number FINCEN-
2020-0003 and OMB control number 1506-0004, 1506-0005, and 1506-0064.
Please submit comments by one method only. Comments will also be
incorporated into FinCEN's review of existing regulations, as provided
by Treasury's 2011 Plan for Retrospective Analysis of Existing Rules.
All comments submitted in response to this notice will become a matter
of public record. Therefore, you should submit only information that
you wish to make publicly available.
FOR FURTHER INFORMATION CONTACT: The FinCEN Regulatory Support Section
at 1-800-767-2825 or electronically at [email protected].
SUPPLEMENTARY INFORMATION:
I. Statutory and Regulatory Provisions
The legislative framework generally referred to as the Bank Secrecy
Act (BSA) consists of the Currency and Financial Transactions Reporting
Act of 1970, as amended by the Uniting and Strengthening America by
Providing Appropriate Tools Required to Intercept and Obstruct
Terrorism Act of 2001 (USA PATRIOT Act) (Pub. L. 107-56) and other
legislation. The BSA is codified at 12 U.S.C. 1829b, 12 U.S.C. 1951-
1959, 31 U.S.C. 5311-5314 and 5316-5332, and notes thereto, with
implementing regulations at 31 CFR Chapter X.
The BSA authorizes the Secretary of the Treasury, inter alia, to
require financial institutions to keep records and file reports that
are determined to have a high degree of usefulness in criminal, tax,
and regulatory matters, or in the conduct of intelligence or counter-
intelligence activities, to protect against international terrorism,
and to implement counter-money laundering programs and compliance
procedures.\1\ Regulations implementing Title II of the BSA appear at
31 CFR Chapter X. The authority of the Secretary to administer the BSA
has been delegated to the Director of FinCEN.\2\
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\1\ Language expanding the scope of the BSA to intelligence or
counter-intelligence activities to protect against international
terrorism was added by Section 358 of the USA Patriot Act.
\2\ Treasury Order 180-01 (re-affirmed Jan. 14, 2020).
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Under 31 U.S.C. 5313, the Secretary of the Treasury is authorized
to require financial institutions to report currency transactions
exceeding $10,000. Regulations implementing 31 U.S.C. 5313 are found at
31 CFR 1010.310 through 1010.314, 31 CFR 1021.311, and 31 CFR 1021.313.
Generally, information collected pursuant to the BSA is confidential,
but may be shared as provided by law with regulatory and law
enforcement authorities.
II. Paperwork Reduction Act (PRA) \3\
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\3\ Public Law 104-13, 44 U.S.C. 3506(c)(2)(A).
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Title: Reports of Transactions in Currency by Financial
Institutions (31 CFR 1010.310 through 1010.314, 31 CFR 1021.311, and 31
CFR 1021.313).
OMB Control Numbers: 1506-0004, 1506-0005, and 1506-0064.\4\
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\4\ The reports of transactions in currency regulatory
requirements are currently covered under the following OMB control
numbers: 1506-0004 (General provisions--31 CFR 1010.310--Reports of
transactions in currency, 31 CFR 1010.311--Filing obligations for
reports of transactions in currency, 31 CFR 1010.312--Identification
required, 31 CFR 1010.313--Aggregation, and 31 CFR 1010.314--
Structured transactions), and 1506-0005 (Rules for casinos and card
clubs--31 CFR 1021.311--Reports of transaction in currency, and 31
CFR 1021.313--Aggregation). OMB control number 1506-0064 applies to
FinCEN Report 112--CTR.
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Report Number: FinCEN Report 112--Currency Transaction Report
(CTR).
Abstract: FinCEN is issuing this notice to renew the OMB control
numbers for the CTR regulations and the CTR report.
Type of Review: Renewal without change of currently approved
information collections.
Affected Public: Businesses or other for-profit institutions, and
non-profit institutions.
CTR Regulations
Estimated Burden: An administrative burden of one hour is assigned
to each of the CTR regulation OMB control numbers in order to maintain
the requirements in force.\5\ The reporting and recordkeeping burden is
reflected in FinCEN Report 112--CTR, under OMB control number 1506-
0064. The rationale for assigning one burden hour to each of the CTR
regulation OMB control numbers is that the annual burden hours would be
double counted if FinCEN estimated burden in each CTR regulation OMB
control number and in the FinCEN Report 112--CTR OMB control number.
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\5\ One hour of burden is estimated under each of the following
OMB control numbers: 1506-0004 and 1506-0005.
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FinCEN Report 112--CTR
Type of Review:
Propose for review and comment a re-calculation of the
portion of the PRA burden that has been subject to notice and comment
in the past.
Propose for review and comment a method to estimate the
portion of the PRA burden that FinCEN previously had not included.
Frequency: As required.
Estimated Reporting and Recordkeeping Burden: The total estimate of
the annual reporting and recordkeeping burden contained herein consists
of two parts: (a) a re-calculation of the portion of the PRA burden
that FinCEN traditionally included in its PRA renewal notices (the
``traditional PRA burden calculation''); and (b) an estimate of the
portion of the total burden that FinCEN previously did not include in
its PRA calculations (the ``supplemental PRA burden calculation'').
[[Page 29023]]
FinCEN's traditional annual PRA burden calculation associated with
the CTR previously included only the filer's annual operational burden
and cost associated with (a) producing and filing the report, and (b)
storing a copy of the filed report. Starting with the current PRA
renewal notice, FinCEN intends to add a supplemental PRA burden
calculation, reflecting the annual costs involved in (a) obtaining data
required by the report that the filer does not need for its own
bookkeeping, and (b) maintaining, updating, and upgrading the
technological infrastructure required to file and store the report.
Part 1. Breakdown of the 2019 CTR Filings
In 2019, 14,276 individual filers (the filing population) submitted
16,087,182 CTRs (the 2019 CTR submissions). To present a more complete
breakdown of the 2019 filing population, FinCEN grouped filers into
twelve tranches according to the range of CTRs filed during the year.
The tranches are listed in descending order starting with filers
accounting for the most CTRs filed annually (``01_LARGEST FILERS''), to
filers submitting six or fewer CTRs annually (``12_1-6/YEAR), as set
out in Table 1 below.\6\
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\6\ The category ``Other'' includes filers belonging to other
types of financial institutions than the ones identified in the
table (such as insurance companies and mutual funds), and some
filers where the type of financial institution was undetermined at
the time of the tabulation.
Table 1--2019 Filers, by Range of the Number of Reports Filed (Tranches), and Type of Financial Institution
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Casino card club Depository institution Money services Other Securities/futures
Total Total ------------------------------------------------ business (MSB) -----------------------------------------------
Tranche filers reports ------------------------
Filers Reports Filers Reports Filers Reports Filers Reports Filers Reports
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
01_LARGEST_FILERS............................... 19 7,971,675 .......... .......... 19 7,971,675
02_100-2000/WEEK................................ 287 4,434,506 73 946 507 206 3,393,315 5 33,515 3 61,169
03_50-99/WEEK................................... 262 925,809 56 198,827 188 656,924 17 67,414 1 2,644
04_10-49/WEEK................................... 1,562 1,723,657 159 195,821 1,224 1,336,193 167 176,148 12 15,495
05_5-9/WEEK..................................... 1,296 487,224 87 33,547 1,029 387,095 172 63,774 8 2,898
06_121-259/YEAR................................. 1,632 292,595 77 13,943 1,281 229,059 263 47,459 9 1,749 2 385
07_73-120/YEAR.................................. 1,102 104,671 53 5,141 821 78,048 206 19,443 22 2,039
08_37-72/YEAR................................... 1,531 80,568 66 3,406 1,152 60,985 278 14,432 35 1,745
09_25-36/YEAR................................... 808 24,433 28 835 588 17,838 170 5,103 21 627 1 30
10_13-24/YEAR................................... 1,323 23,596 41 722 917 16,355 310 5,556 54 946 1 17
11_7-12/YEAR.................................... 1,089 10,122 39 369 656 6,138 323 2,975 71 640
12_1-6/YEAR..................................... 3,365 8,326 106 273 1,519 4,098 1,188 2,784 547 1,158 5 13
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Grand Total................................. 14,276 16,087,182 785 1,399,301 9,600 14,157,723 3,099 438,603 783 9,110 9 445
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Table 1 illustrates that in 2019, 19 filers (all of them depository
institutions) filed almost half of the 2019 CTR submissions (7,971,675
reports). These large filers submitted in excess of 2,000 reports per
week.\7\ Adding these numbers to the submissions of filers that filed
between 100 and 2,000 reports per week, totals 306 individual filers
(or slightly over 2% of the filing population), accounting for over
three-quarters of the 2019 CTR submissions (12,406,181 reports).\8\
Furthermore, depository institutions represent two-thirds of the filing
population, and filed 88% of the 2019 CTR submissions. The high
concentration of filings in a very small fraction of the filing
population, and the preponderance of depository institutions at any
tranche level will impact the averages of both burden and cost.\9\
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\7\ The annual range of the number of reports filed by each
large filer is between 110,000 and nearly 2,000,000 reports per
year.
\8\ The 19 largest CTR filers plus 287 filers reporting between
100 and 2,000 CTRs per week, totals 306 filers. 7,971,675 CTRs
reported by the 19 largest filers plus 4,434,506 CTRs reported by
filers reporting between 100 and 2,000 CTRs per week, totals
12,406,181 reports.
\9\ As large filers that are depository institutions account for
a very large percentage of the 2019 CTR submissions, the general
averages of burden and cost for the filer population will be greatly
affected by the characteristics of the filings of depository
institutions belonging to the first two tranches.
---------------------------------------------------------------------------
All filers submit their reports electronically, either in batch or
discrete form.\10\ Table 2 below sets out the distribution of the 2019
CTR submissions by tranche, filing method, and type of financial
institution.
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\10\ In batch-filing, a filer submits a single electronic file
containing several reports. In discrete-filing, the filer fills in
an electronic form individually, using a data entry screen that
FinCEN provides. While exceptions apply, batch-filing is generally
used by large-volume filers that have automated the filing process,
while discrete-filing is generally employed by filers that submit
fewer forms per year and rely more on manual data entry methods.
Table 2--Break-down of 2018 CTR Submissions, by Tranche, Filing Method, and Type of Financial Institution
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Reports Casino card club Depository Money services Other Securities/futures
--------------------------------------------------------- institution business (MSB) -------------------------------------------
Tranche ---------------------------------------------
Batch Discrete Total Batch Discrete Batch Discrete Batch Discrete Batch Discrete Batch Discrete
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
01_LARGEST_FILERS............................. 7,937,017 34,658 7,971,675 ......... 19 7,937,017 34,658
02_100-2000/WEEK.............................. 4,304,983 129,523 443,4506 924,763 21,744 3,318,491 7,4824 12,621 20,894 49,108 12,061
03_50-99/WEEK................................. 835,918 89,891 925,809 170,474 28,353 627,595 29,329 37,849 29,565 ......... 2644
04_10-49/WEEK................................. 1,261,192 462,465 1,723,657 133,909 61,912 1,101,645 234,548 24,353 151,795 1,285 14210
05_5-9/WEEK................................... 265,191 222,033 487,224 16,806 16,651 243,531 143,564 4,854 58,920 ......... 2898
06_121-259/YEAR............................... 111,215 181,380 292,595 5,175 8,768 102,810 126,249 2,971 44,488 ......... 2,039 385
07_73-120/YEAR................................ 29,528 75,143 104,671 1,244 3,897 26,875 51,173 1,409 18,034 ......... 2,039
08_37-72/YEAR................................. 16,042 64,526 80,568 757 2,649 14,430 46,555 855 13,577 ......... 1,745
09_25-36/YEAR................................. 3,289 21,144 24,433 188 647 2,836 15,002 265 4,838 ......... 627 ......... 30
10_13-24/YEAR................................. 2,993 21,303 23,596 67 655 1,942 14,413 263 5,293 21 925 17
11_7-12/YEAR.................................. 688 9,434 10,122 49 320 503 5,635 136 2,839 640
12_1-6/YEAR................................... 347 7,979 8,326 34 239 146 3,952 158 2,626 9 1,149 13
-------------------------------------------------------------------------------------------------------------------------------------------------
Grand Total............................... 14,767,703 1,319,479 16,087,182 1,253,466 145,835 13,377,821 779,902 85,734 352,869 50,423 40,687 259 186
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[[Page 29024]]
Table 2 shows that, in the aggregate, there is a marked
predilection for batch filing among the filing population (92% of the
2019 CTR submissions were batch-filed). However, filers belonging to
any tranche combine batch and discrete filing, with the preference
shifting from batch filing to discrete filing as the number of reports
filed per year goes down. The aggregate percentages also are influenced
by the concentration of submissions in the first two tranches, and in
the preponderance of depository institutions in the filing population.
When focusing on individual types of financial institution, the
percentage of batch filings vary significantly (money services
businesses (MSBs), for example, file only 20% of their reports in batch
form).
The CTR requires the identification of persons (i.e., entities or
individuals) that fulfill certain roles in the transaction or group of
transactions reflected in each report, either as principals (e.g., a
person that conducts a transaction on its own behalf, or a person on
whose behalf a transaction is conducted), or non-principals (e.g., a
person that conducts a transaction on behalf of another person, or any
currency transporters not hired by the filer itself). The number of
persons per CTR varies significantly among the 2019 CTR submissions.
Breakdowns of those transactions, however, are available where a person
operated on its own behalf, or where the person operating on behalf of
another did not need to be identified (e.g., transactions conducted
through ATMs, night deposit windows, or transported by currency
transporters hired by the filer). Table 3 below sets out the
breakdowns.
Table 3--Breakdown by Tranche and Type of Person Identified in the CTR
[Number of reports]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Conducted on own behalf Information on transactor not
------------------------------------- required
Tranche ------------------------------------- Total
Depository Non- Total Non-
depository Depository depository Total
--------------------------------------------------------------------------------------------------------------------------------------------------------
01_LARGEST_FILE.................................................... 2,289,162 ........... 2,289,162 2,279,428 ........... 2,279,428 4,568,590
02_100-2000/WEEK................................................... 825,683 961,259 1,786,942 660,123 69,132 729,255 2,447,065
03_50-99/WEEK...................................................... 183,055 227,272 410,327 109,655 5,273 114,928 519,982
04_10-49/WEEK...................................................... 510,531 277,878 788,409 239,409 23,918 263,327 1,027,818
05_5-9/WEEK........................................................ 189,273 68,176 257,449 68,963 4,591 73,554 326,412
06_121-259/YEAR.................................................... 128,231 43,146 171,377 41,436 5,734 47,170 212,813
07_73-120/YEAR..................................................... 49,264 18,927 68,191 14,223 2,006 16,229 82,414
08_37-72/YEAR...................................................... 42,521 15,155 57,676 10,321 1,583 11,904 67,997
09_25-36/YEAR...................................................... 13,242 5,637 18,879 2,545 268 2,813 21,424
010_13-24/YEAR..................................................... 12,913 5,895 18,808 2,209 326 2,535 21,017
011_7-12/YEAR...................................................... 5,073 3,398 8,471 625 284 909 9,096
012_1-6/YEAR....................................................... 3,535 3,456 6,991 379 403 782 7,370
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Grand Total.................................................... 4,252,483 1,630,199 5,882,682 3,429,316 113,518 3,542,834 9,311,998
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In general, depository institutions will only accept reportable
transactions in currency from established customers subject to the
institution's customer identification program (CIP).\11\ Therefore, if
a depository institution's CTR identifies only one type of person,
typically that person is either an established customer operating on
its own behalf, or the person on whose behalf the transaction is
conducted is an established customer and the transaction is conducted
through a transactor that does not need to be identified. In these
cases, a depository institution's CIP records for established customers
would provide the identifying information needed to complete a CTR. In
addition, as a prudential matter and prior to completing a transaction,
depository institutions, for example, request identification documents
such as a driver's license to verify the identity of the customer to
protect against fraud. Table 3 shows that depository institutions filed
7,681,799 reports (or 54% of their 2019 CTR submissions) where the only
person identified in the report was the person subject to the filer's
CIP requirements.
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\11\ For a description of the customer identification program
requirements, see 31 CFR 1001.220 and Subpart B of 31 CFR Chapter X.
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Part 2. Re-Calculation of the Traditional Annual PRA Burden and Cost
Traditional Annual PRA Burden (Expressed in Hours)
To comply with their BSA currency transaction reporting
requirement, filers must implement, operate, and supervise a process
that may be broken down into the following steps:
Step 1: Determine whether the filer must report a currency
transaction or group of transactions, based on the amount of a
transaction, the aggregation of multiple transactions at the end of the
day, and certain characteristics of the established customer, the
transaction, or the transactor (such as whether a depository
institution filer has exempted an account of an established customer
from CTR filing). All these determinations are based on objective
parameters.
Step 2: Obtain the information required by the CTR on
parties to the transaction that the filer has not already identified as
part of (i) its normal business operations, (ii) another BSA
requirement (such as CIP), or (iii) another regulatory requirement that
is not BSA-related. Some types of financial institutions filing CTRs
(e.g., depository institutions) will already maintain most, if not all,
the information on parties to the transaction in their customer
database and accounting records.
Step 3: Complete the CTR with the information on the
transaction and the parties involved. The completion of the report will
vary, depending on the technology available to the filer, from a fully-
automated process requiring no manual data entry, to a process that is
nearly entirely manual.
Step 4: The filer will submit the report electronically,
either as a batch or discrete filing. The method of submission does not
necessarily indicate the level of automation of a financial
institution's CTR filing process. For example, some filers that submit
few reports a year batch file, while other filers that submit more
reports may use discrete filing because they have incorporated into
their CTR
[[Page 29025]]
filing process software tools that fill in each form automatically and
release it after manual review of the content.
Step 5: After filing, the filer must store the report for
the regulatory recordkeeping period. As the submission consists of an
electronic file containing one or several reports, the recordkeeping
will be done electronically too.
The greater the reliance on automation, the greater the periodic
cost involved in maintaining, updating, and upgrading the systems and
tools that either link the filer's different applications to obtain the
required source data, or that are used for the CTR completion,
submission, and storage steps.
FinCEN's estimate of the traditional annual hourly burden of the
CTR reporting and recordkeeping requirements only takes into
consideration the time required to complete, submit, and store the
report (Steps 3 to 5 in the process described above).
FinCEN has maintained the same method to calculate the CTR PRA
burden hour estimate since 2002, when paper reports typically were
filled in manually, mailed to the Internal Revenue Service, and
uploaded individually. Under this method, the burden estimates per CTR
were 20 minutes for reporting, and 20 minutes for recordkeeping per
report, regardless of the type of financial institution or complexity
of the report. Since 2011, CTRs have been filed electronically, either
in batch or discrete format. FinCEN has concluded that (a) as either
filing method allows the filer to save an electronic copy of the
batched or discrete/individual reports, which satisfies the
recordkeeping part of the requirement, the recordkeeping portion of the
traditional annual PRA burden will be zero, and (b) the reporting
portion of the traditional annual PRA burden will be set at a variable
number of minutes per report that will reflect the (i) type of
financial institution, (ii) range of the number of reports filed per
year, and (iii) filing method.
For purposes of calculating PRA burden and cost, FinCEN used the
2019 CTR submissions as a baseline, stipulating that submissions from
2019 are an appropriate representation of the expected composition of
the filing population and report submissions for the next three years.
FinCEN estimates the time required for reporting a CTR, based on these
parameters, as described in Table 4 below:
Table 4--Traditional Annual PRA Burden Calculations
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Reports Minutes per report Total hours
---------------------------------------------------------------------------------------------------- Grand
Tranche Batch-filed Discrete-filed Batch Discrete total
---------------------------------------------------------------------------- Batch Discrete (hours)
D ND D ND D ND D ND
--------------------------------------------------------------------------------------------------------------------------------------------------------
01_LARGEST_FILERS........................ 7,937,017 0 34,658 0 1 1 20 20 132,284 11,553 143,836
02_100-2000/WEEK......................... 3,318,491 986,492 74,824 54,699 1 1 20 20 71,750 43,174 114,924
All other tranches....................... 2,122,313 403,390 670,420 484,878 20 20 20 20 841,901 385,099 1,227,000
--------------------------------------------------------------------------------------------------------------
Total................................ 13,377,821 1,389,882 779,902 539,577 ..... ..... ..... ..... 1,045,934 439,826 1,485,761
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D: Depository Institution.
ND: Non-depository Institution.
The traditional annual PRA burden estimated by this new method
(1,485,761 hours) is significantly lower than what FinCEN had
calculated in the past. Table 4 reflects the following rationale for
purposes of the new estimate:
FinCEN considers the reporting time required by both
depository and non-depository financial institutions belonging to the
same tranche of filers (based on number of reports filed), to be the
same.\12\
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\12\ However, whether the institution is depository or non-
depository will have an effect when combining the traditional annual
PRA burden with the supplemental PRA, as described in Part 3 below.
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FinCEN stipulates that filers submitting 100 reports per
week or more, are doing so in a totally automated way (``fully-
automated filers'').
If a fully-automated filer submits reports through batch
filing, the individual reports and the batch file that contains them
are produced automatically, without manual intervention. The burden of
1 minute per report represents the administrative burden involved in
carrying out, reviewing, and overseeing the process of filing CTRs, and
not just the time of preparation and submission per report which would
be nearly instantaneous, and therefore far lower than 1 minute per
individual report.
Where the filing does not involve a fully-automated filer
submitting reports through batch filing, FinCEN allocates 20 minutes
per report to reports filed on (a) a discrete basis by fully-automated
filers, or (b) either a batch or discrete basis by any filer submitting
fewer than 100 reports per week. The 20 minutes includes the
administrative burden and the actual time required to enter the
individual report in FinCEN's data entry screen, or to complete the
individual report manually before it is added to the batch file. This
allocation of time is extremely conservative: FinCEN is stipulating
that filers submitting fewer than 100 reports per week are not
automated and that, regardless of the filing method, each report will
require full manual data entry intervention. Similarly, FinCEN
stipulates that fully-automated filers that file discretely will not
receive the benefits of any automation, and will incur the same burden
per report.
FinCEN intends to conduct more granular studies of the filing
population in the future, to arrive at more accurate estimates that
take into consideration a more granular breakdown of the degree of
automation among CTR filers. The data obtained in these studies may
result in significant variations of the estimated annual PRA burden
hours.
Cost of the Traditional Annual PRA Burden
To estimate the cost of each hour of the traditional annual PRA
burden, FinCEN identified three types of roles and corresponding staff
positions involved in the reporting and recordkeeping of CTRs: (1)
Remote supervision (general process oversight), (ii) direct supervision
(review of the filing process, and cross-check of filings against
accounting records), and (iii) operations (actual production, filing,
and storage of the reports). FinCEN calculated the fully loaded hourly
wage for each of these three roles by taking the median wage for these
positions as estimated by the U.S. Bureau of Labor Statistics (BLS),
and computing an additional cost of benefits as follows: \13\
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\13\ See U.S. Bureau of Labor Statistics, Occupational
Employment Statistics-National, May 2019, available at https://www.bls.gov/oes/tables.htm. The most recent data from the U.S.
Bureau of Labor Statistics corresponds to May 2019. For benefits
component of total compensation, see U.S. Bureau of Labor
Statistics, Employer's Cost per Employee Compensation as of December
2019, available at https://www.bls.gov/news.release/ecec.nr0.htm.
The ratio between benefits and wages for financial activities,
credit intermediation and related activities is $15.80 (hourly
benefits)/$31.45 (hourly wages) = 0.502. The benefit factor is 1
plus the benefit/wages ratio, or 1.502. Multiplying each hourly wage
by the benefit factor produces the fully-loaded hourly wage per
position.
[[Page 29026]]
Table 5--Total Hourly Remuneration (Fully-Loaded Hourly Wage) per Role and BLS Job Position
----------------------------------------------------------------------------------------------------------------
Median hourly Fully-loaded
Role BLS-Code BLS-Name wage Benefit factor hourly wage
----------------------------------------------------------------------------------------------------------------
Remote Supervision............ 11-3031 Financial $62.45 1.502 $93.80
Manager.
Direct Supervision............ 13-1041 Compliance 33.20 1.502 49.87
Officer.
Operations.................... 43-3071 Teller.......... 15.02 1.502 22.56
----------------------------------------------------------------------------------------------------------------
FinCEN estimates that, on average, each role would spend different
amounts of time on the CTR reporting and recordkeeping requirements.
FinCEN further estimates that the total number of hours of the
traditional annual PRA burden may be allocated to the different roles
as follows: 1% of the burden will represent the work of remote
supervision, 9% of the burden will represent the work of direct
supervision, and the remainder will represent operations work.
Multiplying the fully-loaded hourly wage from Table 5 by the proportion
of time FinCEN estimates each role spends on the CTR process, FinCEN
arrives at a weighted average hourly cost, set out below:
Table 6--Weighted Average Hourly Cost
--------------------------------------------------------------------------------------------------------------------------------------------------------
Remote Supervision Direct supervision Operations Weighted
Component ------------------------------------------------------------------------------ average
% time Hourly cost % time Hourly cost % time Hourly cost hourly cost
--------------------------------------------------------------------------------------------------------------------------------------------------------
Recordkeeping and reporting.................................. 1 $93.80 9 $49.87 90 $22.56 $25.73
--------------------------------------------------------------------------------------------------------------------------------------------------------
FinCEN multiplied the total hours per filer type from Table 4
(1,485,761 hours), by the weighted average hourly cost from Table 6
($25.73 per hour), and estimated the cost of the traditional annual PRA
burden to be $38,228,631.
Part 3. Estimate of the Supplemental Annual PRA Burden
FinCEN intends to add a supplemental PRA burden calculation,
reflecting the annual PRA burden and cost involved in (a) obtaining
data required by the CTR that the filer does not need for its own
bookkeeping, and (b) maintaining, updating, and upgrading the
technological infrastructure required to file and store the CTRs.
Annual Hourly PRA Burden of Obtaining Source Data
For purposes of estimating the annual burden of obtaining and
verifying information on the parties to a reportable transaction or
group of transactions (the ``ID-related annual PRA burden''), FinCEN
consolidates the types of financial institution filing CTRs into two
major groups, depository and non-depository institutions, and
stipulates the following:
1. Depository institutions report CTRs where the principal--the
person on whose behalf the transaction is conducted (either when the
person is operating by itself or through a different person)--is an
established customer subject to CIP.\14\ All depository institutions
verify and record the customer identification information on the
principals required by the CTR. Therefore, FinCEN assigns no PRA burden
to obtaining, verifying, and recording the information on principals of
currency transactions reported by depository institutions (``ID-related
PRA burden'').\15\
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\14\ For the regulatory definition of `established customer',
see 31 CFR 1010.100(p).
\15\ This stipulation is grounded in FinCEN's review of the 2019
CTR submissions. In CTRs filed by depository institutions, the filer
reported a transactional account belonging to either the person
conducting the transaction on its own behalf, or to the person on
whose behalf the transaction was conducted, in over 98% and 94% of
the cases, respectively, while the remaining reports had incomplete
information in the respective sections.
---------------------------------------------------------------------------
2. Non-depository institutions may or may not restrict their
reportable currency transactions to established customers.
Conservatively, FinCEN assigns an ID-related PRA burden of three
minutes per person for a non-depository institution to obtain, verify,
and record the required information to file a CTR on any principal
(either a person conducting a currency transaction on its own behalf,
or a person on whose behalf the transaction was conducted).
3. Neither depository nor non-depository institutions likely
maintain in their records the information required by a CTR about a
person conducting a transaction on behalf of another person. Therefore,
FinCEN assigns an ID-related PRA burden of three minutes per person for
an institution to collect the required information to file a CTR on a
person conducting a transaction on behalf of another person.
4. The CTR requires the reporting of currency transporters
operating on behalf of any party that is not the filer.\16\ The
information required involves the legal person (for example, the
armored car service company), and not the individual natural person
performing the physical transportation. There are a limited number of
currency transporters conducting transactions with depository or non-
depository institutions whose information must be on file for physical
security reasons (such as controlling access to the vault). Therefore,
FinCEN assigns an ID-related PRA burden of one minute per currency
transporter for an institution to collect the required information to
file a CTR on the currency transporter.
---------------------------------------------------------------------------
\16\ See FIN-2013-R001, ``Treatment of Armored Car Service
Transactions Conducted on Behalf of Financial Institution Customers
or Third Parties for Currency Transaction Report Purposes'', July
12, 2013.
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To arrive at the estimate of the total ID-related annual PRA
burden, FinCEN counted the number of each of the four types of persons
(i.e., a person operating on its own behalf, a person on whose behalf
the transaction is conducted, a person conducting the transaction on
[[Page 29027]]
behalf of another, and a currency transporter operating on behalf of a
person other than the filer) in each 2019 CTR submission, and
multiplied the total of each type of person identified in each report
by the corresponding individual ID-related PRA burden, as defined
above. The breakdown of the total ID-related PRA annual burden is
described in Table 7 below.\17\
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\17\ The column ``Principals'' includes the PRA burden of
``persons conducting a transaction on their own behalf'', and
``persons on whose behalf the transaction was conducted'' by
somebody else. The column ``Non_Principals'' includes the PRA burden
of ``persons conducting a transaction on behalf of others'' and
``currency transporters working for a person other than the filer.''
Principals carry a zero PRA burden for depository institutions, and
a 3-minute PRA burden per individual person identified in each
report for non-depository institutions. In the case of Non-
Principals, ``persons conducting a transaction on behalf of others''
carry a 3-minute PRA burden per person identified in each report,
regardless of the filer type, and ``currency transporters working
for a person other than the filer'' carry a PRA burden of one minute
per individual currency transporter identified in each report,
regardless of the filer type.
Table 7--Total Annual PRA Burden of Obtaining and Verifying Personal Information
[Minutes and hours]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Depository Non-depository
TRANCHE ---------------------------------------------------------------- Total minutes Total hours
Principals Non-principals Principals Non-principals
--------------------------------------------------------------------------------------------------------------------------------------------------------
01_LARGEST_FILERS....................................... 0 12,905,258 0 0 12,905,258 215,087
02_100-2000/WEEK........................................ 0 6,973,483 3,179,679 60,264 10,213,426 170,224
All other tranches...................................... 0 4,928,268 2,846,334 640,998 8,415,600 140,260
-----------------------------------------------------------------------------------------------
Total............................................... 0 24,807,009 6,026,013 701,262 31,534,284 525,571
--------------------------------------------------------------------------------------------------------------------------------------------------------
The total ID-related annual PRA burden estimated by this method is
525,571 hours.
Cost of Annual PRA Burden of Obtaining Source Data
FinCEN multiplied the total hours per filer type from Table 7
(525,571 hours), by the weighted average hourly cost from Table 6
($25.73),\18\ and estimated the cost of the total ID-related PRA annual
burden to be $13,522,942.
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\18\ FinCEN stipulates that the weights used to calculate the
weighted average costs in Table 6 are appropriate weights for the
calculation of the weighted average costs for the obtaining of
source data.
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Annual PRA Cost and Burden of Maintaining and Upgrading Hardware and
Software
It is difficult for FinCEN to separately estimate the annual cost
and hourly burden a financial institution bears in maintaining the
hardware and software for the CTR requirement itself (the ``technology-
related annual PRA cost'' and the ``technology-related annual PRA
burden'' of the CTR, respectively). FinCEN understands that most large
financial institutions maintain highly integrated software and hardware
systems for anti-money laundering and safety and soundness purposes
that leverage the existing need to maintain records and information
about customers and transactions for business reasons. Given the
difficulties of calculating such a cost estimate, FinCEN attempted to
estimate a percentage of the supplemental burden for this report using
data collected in a previous rulemaking effort. While not exact, this
is the best information FinCEN currently has to prepare an estimate
which likely represents the outer limit of the technology-related costs
relative to the total cost.
In 2008, FinCEN surveyed certain depository institutions and money
transmitters to assess the costs to set up and maintain the reporting
of cross-border electronic transmittal of funds (CBETF) data above
certain thresholds (the ``2008 Survey'').\19\ Seventy-five depository
institutions and six money transmitters involved in international
transmittals of funds responded to the survey. In the case of
depository institutions, the survey identified proportionally each type
of cost involved in setting up the reporting process, and the ongoing
cost involved in complying annually with the proposed CBETF reporting
obligation.\20\
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\19\ FinCEN's 2008 Cross-Border Electronic Funds Transfer Survey
Final Report is set out in Appendix C of FinCEN's January 2009 study
on the Implications and Benefits of Cross-Border Funds Transmittal
Reporting, available at https://www.fincen.gov/sites/default/files/shared/ImplicationsAndBenefitsOfCBFTR.pdf (``January 2009 Study'').
\20\ Appendix C of the January 2009 Study, page 15.
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The breakdown of the annual ongoing reporting compliance costs is
reflected in Table 8 below.
Table 8--Proportion of Components of Annual PRA Burden
----------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------
PERSONNEL................................................ 45% 85.00%
ONGOING MANAGEMENT....................................... 23.00%
OTHER.................................................... 12.00% COST COMPONENTS INCLUDED IN
TRADITIONAL
TESTING.................................................. 2.00% AND ID-RELATED ANNUAL PRA
BURDEN
TRAINING................................................. 2.00%
CONSULTING............................................... 1.00%
----------------------------------------------------------------------------------------------------------------
HARDWARE................................................. 6.00% COST COMPONENTS NOT INCLUDED IN
IT....................................................... 6.00% 15.00% TRADITIONAL AND ID-RELATED
ANNUAL PRA
SOFTWARE DEVELOPMENT..................................... 3.00% BURDEN
----------------------------------------------------------------------------------------------------------------
TOTAL................................................ 100.00% 100.00%
----------------------------------------------------------------------------------------------------------------
The absolute ongoing cost per component estimated by the 2008
Survey respondents relate to the CBETF reporting, and therefore cannot
be used to extrapolate the costs of another reporting or recordkeeping
requirement.
[[Page 29028]]
While the absolute costs may not be extrapolated to another
requirement, the proportion of the annual ongoing compliance costs
provided by the depository institution respondents to the 2008 Survey
can be used to extrapolate an estimate of the technology-related PRA
cost (15% of the total cost) for fully-automated filers. FinCEN
assesses such a method is valid because the CTR and CBETF reporting and
recordkeeping requirements are similar with respect to the objective
nature of the reporting triggered by threshold amounts of transactions.
Given the limited information at its disposal regarding the technology-
related costs associated with the filing of CTRs, FinCEN is using the
proportions of the cost components reported by depository institutions
to extrapolate the total annual technology-related PRA cost, as CTRs
filed by depository institutions represent 88% of all CTRs filed in
2019. In addition, FinCEN believes the proportionality of ongoing costs
derived from the 2008 Survey is still useful today notwithstanding
changes in costs over time. Not only has the cost of hardware dropped
considerably between 2008 and 2019, but the personnel cost associated
with software development and information technology management has
increased on par with, or slightly less than, the cost of personnel
included in the traditional PRA estimate; in other words, the changes
in costs of the different components of the information technology
investment have grown at a slower pace than the traditional annual PRA
cost estimate.\21\
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\21\ See footnote 8. See also, Bureau of Labor Statistics,
Occupational Employment Statistics-National, May 2008, available at
https://www.bls.gov/oes/tables.htm. Between 2008 and 2019, for
example, the median hourly wage for financial managers, compliance
officers, and tellers went up 17.41%, 28.43%, and 28.82%,
respectively, while the same metric went up only 8.27% and 20.03%
for software developers and programmers and network and computer
system administrators, respectively.
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Based on the revised estimate of the traditional annual PRA burden
(as described in Part 2 above), and the estimate of the additional ID-
related annual PRA burden described in the earlier sections of this
Part, the PRA burden and cost for all filers (without including a
technology component) are described in Table 9 and Table 10 below,
respectively.
[GRAPHIC] [TIFF OMITTED] TN14MY20.030
Based on the proportions described in Table 8 above, the
traditional and ID-related annual PRA costs of fully-automated filers
estimated in Table 10 (the ``Table 10 PRA cost'') constitute 85% of the
total annual PRA cost of reporting and recordkeeping incurred by such
filers, with the remaining 15% of costs corresponding to the
technology-related PRA cost (i.e., maintenance, updates and upgrades of
software, general information technology support, and hardware
replacement). To estimate the total annual PRA costs for fully-
automated filers to file CTRs (a calculation that adds the cost of the
traditional and ID-related annual PRA burden to the newly estimated
technology-related PRA cost), FinCEN discounts the Table 10 PRA cost by
its contribution to the total annual PRA cost ($16,571,966/0.85),
resulting in a total annual PRA cost for fully-automated filers of
$19,496,430.
Determining the hourly burden of some cost components of the
technology-related annual PRA burden, such as the price of new
hardware, is not straightforward. The method FinCEN followed to
estimate the technology-related annual PRA cost does not provide a
definitive way for deriving the burden hours attributable to each cost
component. To produce such an estimate, FinCEN would have needed
information not provided in the 2008 Survey (such as the participation
of different levels of technology-related labor and their fully-loaded
compensation rates). FinCEN, however, believes that it is appropriate
to estimate the total annual PRA hourly burden for fully-automated
filers using a calculation similar to the one employed for the total
annual PRA cost. FinCEN stipulates that the traditional and ID-related
PRA burden for fully-automated filers set out in Table 9 above (the
``Table 9 PRA burden'') also constitutes 85% of the total annual PRA
burden of such filers. FinCEN discounts the Table 9 PRA burden by its
contribution to the total annual PRA burden (644,072 hours/0.85), and
arrives at a total annual
[[Page 29029]]
PRA burden for fully-automated filers of 757,732 hours.\22\ This equals
the sum of the traditional annual PRA burden and the ID-related annual
PRA burden (644,072 hours or 38,644,260 minutes), and the technology-
related annual PRA burden (113,660 hours or 6,819,583 minutes).
---------------------------------------------------------------------------
\22\ This calculation uses the cost per burden hour estimate of
$25.73 per hour derived through the previous estimates even though
the costs per hour in the context of maintaining, updating, and
upgrading the hardware and software are different. Of importance
here is FinCEN's confidence in the overall costs reflected in this
assessment, even if there is less confidence in the notional number
of burden hours associated with the supplemental cost.
---------------------------------------------------------------------------
In the future, FinCEN intends to conduct studies of the filing
population to more accurately estimate the contribution of technology-
related costs to the total annual PRA burden. These future studies will
incorporate a more granular breakdown of the degree of automation among
CTR filers, and may result in significant variations of the estimated
annual PRA burden. Among other things, FinCEN will need to segregate
the technology costs associated exclusively with BSA reporting,
recordkeeping, and monitoring requirements, from the technology costs
involved in (i) complying with other regulatory frameworks, and/or (ii)
processing data used for the filer's other business purposes.
Estimated Reporting and Recordkeeping Burden: The average estimated
PRA burden, measured in minutes per report, is 8 minutes, as described
in Table 11 below:
[GRAPHIC] [TIFF OMITTED] TN14MY20.031
Estimated Number of Respondents: 14,276 financial institutions.\23\
---------------------------------------------------------------------------
\23\ See Part 1-Table 1 for a breakdown of the types of
financial institutions that filed CTRs in 2019. Note that all banks,
casinos and card clubs, MSBs, brokers or dealers in securities,
mutual funds, futures commissions merchants and introducing brokers
in commodities are required to comply with the CTR regulatory
requirement, however, not all financial institutions conduct
transactions that would trigger the CTR filing requirements. See 31
CFR 1020.310 (banks), 31 CFR 1021.310 (casinos and card clubs), 31
CFR 1022.310 (MSBs), 31 CFR 1023.310 (brokers or dealers in
securities), 31 CFR 1024.310 (mutual funds), and 31 CFR 1026.310
(futures commissions merchants and introducing brokers in
commodities).
---------------------------------------------------------------------------
Estimated Total Annual Responses: 16,087,182.\24\
---------------------------------------------------------------------------
\24\ Numbers are based on actual 2019 filings as reported by the
BSA E-Filing System as of 12/31/2019. This number reflects the total
number of filings for both the legacy CTR and CTRC and the new
FinCEN Report 112--CTR.
---------------------------------------------------------------------------
Estimated Total Annual Reporting and Recordkeeping Burden: The
estimated total annual PRA burden is 2,124,992 hours, as described in
Table 12 below.
[GRAPHIC] [TIFF OMITTED] TN14MY20.032
Estimated Total Annual Reporting and Recordkeeping Cost: At the
weighted average hourly cost of $25.73 described in Table 6 above, the
cost of the estimated total annual PRA reflected in Table 12 (2,124,992
hours) is $54,676,044.
An Agency may not conduct or sponsor, and a person is not required
to respond to, a collection of information unless the collection of
information displays a valid OMB control number. Records required to be
retained under the BSA must be retained for five years.
Request for Comments
a. Specific Requests for Comments
Comments submitted in response to this notice will be summarized
and/or included in the request for OMB approval. All comments will
become a matter of public record. Comments are invited on the
calculation of the total PRA burden of filing the CTR, under the
current regulatory requirements. Specifically, comments are invited on
the following issues:
1. FinCEN has broken down the process required to comply with the
CTR requirement into several steps, from identifying a transaction that
must be reported, to maintaining and upgrading software required for
the completion, submission, and storage of the report. In general, do
these steps reflect the filer's own general experience? Is there a need
to include a more granular breakdown of the process to describe what,
on average, a CTR filer must do?
2. For purposes of calculating PRA burden and cost, FinCEN has
taken the 2019 CTR submissions number as a baseline, stipulating that
it is an
[[Page 29030]]
appropriate representation of the expected composition of the filing
population and report submissions for the next three years. Is that an
appropriate assumption? Are there expected changes in either the
composition of the filing population or the breakdown of the report
submissions over the next three years that should be factored into
FinCEN's estimates?
3. FinCEN estimates that, on average, the time involved in the
reporting of a CTR varies in accordance with the range of the total
number of reports filed per year (i.e., filers filing 100 reports or
more per week are totally automated), the type of financial institution
and type of transaction (i.e., depository financial institutions
engaging in reportable currency transactions that only involve
established customers), and filing method (i.e., completion of reports
filed on a discrete basis generally involve more manual data entry than
those batch-filed, regardless of the filer's level of automation). Are
these assumptions reasonable? Are there other factors that may affect
the amount of time involved in preparing, reviewing, and filing the
report, which FinCEN could quantify by analyzing the contents of the
BSA database and without conducting a formal survey of the reporting
financial institutions?
4. FinCEN estimates that the completion, review, and submission of
a CTR will demand a certain number of minutes per report, depending on
the factors listed above. On average, is the estimated number of
minutes per report reasonable, by degree of automation of the filer,
type of financial institution the filer is, method of filing, types of
financial institution labor positions involved, and allocated time per
labor position?
5. FinCEN estimates that, on average, the cost of labor involved in
the completion, review, and submission of a CTR will depend on at least
three different levels of staff involvement within the filer's
organization (i.e., remote supervision, direct supervision, and
operations) participating in the process for different portions of the
CTR process. On average, is the allocation of time and hourly cost plus
benefits per organizational level reasonable? Has FinCEN identified the
right level of involvement and the right type of labor position per
role?
6. FinCEN estimated the ID-related PRA burden by stipulating that
depository institutions conduct reportable transactions only with
established customers, while non-depository institutions conduct
transactions with non-established customers. Is this stipulation
reasonable? Is there another factor that would allow FinCEN to
determine when a non-depository institution conducts a transaction with
an established customer, and therefore its ID-related PRA cost is lower
than the current estimate? FinCEN allocated an ID-related PRA cost of
three minutes to persons conducting a transaction on behalf of another,
for any type of financial institution. Is this allocation always
required, or are there instances where the filer has already obtained,
verified, and retained the personal data of the transactor, and
therefore the allocation could be lower, or even eliminated altogether?
7. FinCEN estimated the technology-related PRA burden on the
assumption that, on average, the percentage breakdown of the total cost
among different cost factors is mostly constant among analogous
reporting obligations. Based on a previous industry survey, FinCEN
based the estimates of total annual PRA burden on the premise that
traditional and ID-related annual PRA costs amount to 85% of the total
annual PRA cost of fully-automated filers, while software, hardware,
and systems-related costs, including maintenance, updates and upgrades
represent the remaining 15%. Is there existing evidence that may
indicate that one or both of these assumptions are not reasonable? Is
there another factor or combination of factors that would assist FinCEN
in determining which filers that file fewer than 100 reports a week may
also be fully or partially automated, and therefore adjust the
technology-related PRA cost?
8. The estimate of the technology-related PRA burden relies on the
principle that the system maintenance, hardware maintenance and
replacement, and other technological costs included in the estimate
relate to hardware and software resources used exclusively for CTR
filing. If such resources are used for multiple purposes, only a
fraction of their cost that represents their use for complying with
this BSA obligation should be included in the PRA burden estimate. Is
this assumption correct? Is this assumption provable by objective
methods? Has your financial institution determined what percentage of
its technology is used for CTR purposes? How can FinCEN determine which
resources, if any, are used for purposes other than BSA compliance, and
therefore adjust the PRA estimate?
9. Please provide any other comments on calculation methods,
assumptions, stipulations, or any other issues that may impact the
total PRA burden calculation of the regulations or the report.
b. General Request for Comments
Comments submitted in response to this notice will be summarized
and/or included in the request for OMB approval. All comments will
become a matter of public record. Comments are invited on: (a) Whether
the collection of information is necessary for the proper performance
of the functions of the agency, including whether the information shall
have practical utility; (b) the accuracy of the agency's estimate of
the burden of the collection of information; (c) ways to enhance the
quality, utility, and clarity of the information to be collected; (d)
ways to minimize the burden of the collection of information on
respondents, including through the use of automated collection
techniques or other forms of information technology; and (e) estimates
of capital or start-up costs and costs of operation, maintenance, and
purchase of services to provide information.
Dated: May 8, 2020.
Derek Baldry,
Deputy Chief of Staff, Financial Crimes Enforcement Network.
[FR Doc. 2020-10310 Filed 5-13-20; 8:45 am]
BILLING CODE 4810-02-P
