Oklahoma Bankers Association We make bankers better!
We are almost exactly one year out from the 2026 elections – I know you are counting down the days!
There are a lot of significant state level races and the all-important midterm elections at the federal lev
el. I will touch on this a little later in this article, but for now, I’m excited to bring you some good news out of Washington. Rarely do I have the opportunity to talk about a piece of legislation that is long overdue for a makeover – and it looks like it will get one that will make your life easier.
The Streamline Act was recently introduced by Sen. Tim Scott (R-S.C.), chairman of the Senate Banking Committee, Sen. John Kennedy (R-La.) and several others. This Act will increase the CTR threshold from $3,000 to $30,000 and the SAR threshold from $2,000 to $3,000.
Before we talk about why this is a good bill, let’s remember how we got here. Banks didn’t have to use the CTR until 1970 when President Richard Nixon signed the Bank Secrecy Act into law. The BSA was established to stop criminals from using the banking system to hide their “ill-gotten gains” or launder money. Prior to 1970, the only way a suspicious transaction was reported to the government was if a teller called law enforcement.
Suspicious activity reports have been part of the anti-money laundering statutes and regulations since the BSA became law. In 2001, the USA Patriot Act expanded the requirements for what constitutes suspicious activity to battle domestic and global terrorism. While looking at the history of these two requirements, I quickly realized the rabbit hole of data I went down while studying up on all this is really fascinating, I’ll share a little bit of what I found.
CTR
According to the U.S. Government Accountability Office, law enforcement only accessed 5.4% of all CTRs filed. Given the dated reporting thresholds, which were set at $10,000 in 1972 (CTR) and $5,000 in 1996 (SAR), resulting in the voluminous reports to law enforcement, it is questionable as to whether the current thresholds meaningfully assist law enforcement.
The Bipartisan Policy Center notes that in 1972 the typical household could take their entire annual earnings and deposit it in cash without triggering the need to file a CTR. The GAO reported the inflation-adjusted threshold would be approximately $72,880 in 2023. As a result of this, over 20 million CTRs are now filed annually, 1 for every 16 Americans.
As a micro-example, a $2 billion community bank noted that from Jan. 1, 2024 to Sept. 30, 2025, they filed 2,958 CTRs. If that threshold was set at $30,000 over the same period, the same bank would have reduced its CTR filings to 377, providing law enforcement with a more meaningful pool of potential CTRs for investigation.
If the higher reporting threshold is extrapolated to the entire industry, it is easy to see how the more targeted reports will provide more useful information to law enforcement while at the same time reducing the reporting burden for customers and banks.
SAR
Over a third of SARs filed by banks are due to customers’ structuring transactions to avoid CTR reporting. Diverting bank resources to these types of SAR filings results in reducing a bank’s ability to focus on more serious instances of suspicious activity.
The outdated CTR threshold of $10,000 has created a cascade of additionally onerous filings, adding to the challenge of sifting through meaningful suspicious activity.
By way of another micro-example, that same aforementioned $2 billion bank filed 340 SARs from Jan. 1, 2024, to Sept. 30, 2025. Of those, 245 were due directly to structuring. Again, this is just one specific example that excess information is being generated, which is not additive to the goals of law enforcement and instead may be impeding their efforts.
While nothing is guaranteed in Washington, we do have all the right people supporting this bill to get it across the finish line. One of the best parts of the Streamline Act is it instructs the Treasury Department to adjust these numbers for inflation every five years, that should keep us from having to do this again in 10-15 years.
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Earlier I mentioned we are a year away from the 2026 general election. We’ll have plenty of time to talk about the different candidates at the state and federal level the closer we get. But, one issue I want to make sure you are aware of and have all the information you need regards State Question 836.
What does SQ 836 do? It would establish open primaries for statewide and county offices, district attorney, state legislators and congressional candidates where candidates for an office appear on one ballot, regardless of party, with top-two vote-getters moving forward to the general election.
A top-two primary is a type of primary election where all candidates are listed on the same ballot. The top two vote getters advance to the general election regardless of their party affiliation. Consequently, it is possible for two candidates belonging to the same political party to win a top-two primary and face off in the general election.
Right now, they are in the signature gathering stage of SQ 836. In Oklahoma, the number of signatures required to get the state question on next year’s ballot is equal to 15% of the votes cast in the last gubernatorial election. The places the number of signatures for this state question to be on the ballot at 172,993.
Should you need any additional information of have any questions regarding SQ 836 please don’t hesitate to reach out.