Potential CTR Changes

34. If the CTR filing threshold were to increase, for example from $10,000 to $20,000, how much of a reduction, if any, would there be in the usefulness of the CTR filing requirement to your agency’s work?
1.
2.
3.
4.
5.
6.

35. How would your agency's work be affected, if at all, by this increase in the CTR filing threshold? Please describe below.

36. If depository institutions were no longer required to file CTRs on the transactions of the businesses listed in the table below, how much, if any, of a reduction would there be in the ability of your agency to use CTRs as investigative leads or evidence?
    Very great reduction Great reduction Moderate reduction Some reduction Little or no reduction Don't know
  a. Businesses that serve as financial institutions or agents of financial institutions of any type (e.g., money services businesses or “MSBs”)
  b. Businesses that purchase or sell motor vehicles or any kind of vessels, aircraft, farm equipment, or mobile homes
  c. Businesses that practice law, accountancy, or medicine
  d. Businesses that auction goods
  e. Businesses that charter or operate ships, buses, or aircraft
  f. Gaming businesses of any kind (other than licensed pari-mutuel betting at race tracks)
   

    Very great reduction Great reduction Moderate reduction Some reduction Little or no reduction Don't know
  g. Investment advisory services or investment banking services
  h. Real estate brokerage
  i. Pawn brokerage
  j. Title insurance and real estate closing firms
  k. Businesses with trade union activities
   

37. Are there any other options you could suggest for modifying CTR filing requirements?


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