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August 2006

Corporate Credit Unions’ Currency Transaction Reporting Obligations

Dear [ ]: I am writing in response to your letter of June 7, 2006 to the U.S. Department of the Treasury, in which you request an administrative ruling on behalf of [ ] that addresses whether the Bank Secrecy Act and its implementing regulations require corporate credit unions to file Currency Transaction Reports (CTRs).1 Your letter was forwarded to the Financial Crimes Enforcement Network (FinCEN) as the delegated administrator of the Bank Secrecy Act, and I understand that you have also discussed these and related issues with FinCEN Regulatory Helpline staff.