What FinCEN’s Time Burden Estimate for new CTRs Fails to Take Into Account
FinCEN estimates the time burden to complete the new CTR would be a total of 45 minutes per filing. Even if that estimate were accurate, it fails to take into account all the significant operational and recordkeeping changes needed before a bank could file its first new CTR. That runs counter to the Paperwork Reduction Act, especially in light of Executive Order 13563, which emphasizes the importance of reducing regulatory burdens and costs. [4/5/16]


