The Board of Governors of the Federal Reserve System and the Financial Crimes Enforcement Network (agencies) issued a joint notice of proposed rulemaking on October 27, 2020 to lower the threshold for rules related to recording and transmitting information on certain funds transfers and transmittals of funds. The Recordkeeping Rule requires financial institutions to collect and retain information related to funds transfers and transmittals. The Travel Rule requires financial institutions to transmit information on certain funds transfers and transmittals of funds to other financial institutions participating in the transmittal. Both Rules apply to amounts of funds in amounts of $3,000 or more. The agencies have proposed to reduce this threshold to $250. 
 
WBA submitted comments to oppose the threshold reduction, pointing to increased burdens it would create as a result of necessary procedure and software changes. The proposal would also redefine the term “money” for purposes of defining “payment order” and “transmittal order” in order to clarify those terms include convertible virtual currency. Because Wisconsin law does not define virtual currency, WBA requested the agencies provide a better definition of virtual currencies. Click here to view the letter.