Compliance reporting.

The reports, deadlines and records a bank or credit union compliance team owns, on one calendar, with a guide to each.

How AI coworkers can help

Compliance reporting is the recurring work a bank or credit union compliance team owns: the reports it files, the deadlines they run on, and the records that prove the work. Currency transaction reports, suspicious activity reports and HMDA data each run on their own clock.

In fiscal 2025, FinCEN received about 21.5 million currency transaction reports and 4.8 million suspicious activity reports from banks and other filers.⁠[1] This page puts a compliance team's deadlines on one calendar, with what the work costs and where AI coworkers fit.

Compliance guides

The compliance calendar

Each report runs on its own clock, and each clock starts from its own trigger: a cash transaction, the day suspicion is detected, the end of a quarter or a year, the last exam, the date of filing. These six span days to years, so the scale below is logarithmic.

Currency transaction report (CTR)15 days from the transaction

A CTR is filed for each deposit, withdrawal, exchange or other transfer of currency of more than $10,000. Cash transactions the bank knows are by or for the same person count as one when the cash in, or the cash out, totals more than $10,000 in a business day, across all domestic branches. Exemptions are in BSA compliance.

31 CFR 1010.311, 1010.313, 1010.306(a)(1)⁠[2]

Suspicious activity report (SAR)30 calendar days from initial detection

A SAR is due no later than 30 calendar days after the bank first detects facts that may constitute a basis for filing. If no suspect has been identified, it may take another 30 days to identify one, but never more than 60 days from detection. The 90/120-day continuing-activity cadence has been optional since October 9, 2025. Thresholds and the narrative are in SAR filing.

31 CFR 1020.320(b)(3) · 12 CFR 21.11(d), 208.62(d), 353.3(b)(1), 748.1(d)(2)(i)⁠[3]⁠[4]⁠[5]⁠[6]⁠[7]⁠[8]

Quarterly HMDA filing for large reporters60 calendar days after Q1, Q2 and Q3

An institution that reported at least 60,000 covered loans and applications for the preceding year, excluding purchased loans, also files its data for each of the first three quarters. Every reporter records each application on its register within 30 calendar days after the end of the quarter in which it took final action.

12 CFR 1003.5(a)(1)(ii), 1003.4(f)⁠[9]

Annual HMDA filingMarch 1 of the following year

File the loan/application register on the HMDA Platform, correct or confirm every edit, and have an authorized representative with knowledge of the data certify that it is accurate and complete. Keep a copy of the register for at least three years. Who must report is in HMDA reporting.

12 CFR 1003.5(a)(1)(i), (iii), (a)(3)⁠[9]⁠[10]

Full-scope exam, for banks12 or 18 months between exams

For banks, the law generally requires a full-scope, on-site exam every 12 months. Since September 14, 2026, qualifying banks under $6 billion can be examined every 18 months; the threshold was $3 billion, and the agencies estimate 4,016 institutions may now qualify. They can still examine any bank more often. The rule comes from the OCC, the Federal Reserve and the FDIC, so it doesn't cover credit unions.

12 CFR 4.6(b), 208.64(b), 337.12(b)⁠[11]

SAR and CTR recordsFive years from filing

Keep each SAR with its supporting documentation, and each CTR, for five years, stored so it can be retrieved within a reasonable time. SAR supporting documentation is deemed filed with the SAR and must be made available to FinCEN, law enforcement and examiners on request.

31 CFR 1020.320(d), 1010.306(a)(2), 1010.430(d)⁠[3]⁠[2]

What compliance costs

There is no single official figure, and FinCEN says public data on compliance costs are scarce.⁠[12] The best estimates come from FinCEN and from the Conference of State Bank Supervisors (CSBS), which surveys community banks every year.

  • About $598,700 a year is FinCEN's estimate of what a bank or credit union spends on its anti-money laundering program alone, as a size-weighted average. The median is $414,300.⁠[12]
  • Over $6 billion a year is FinCEN's estimate of the reporting and recordkeeping part of BSA compliance alone, in aggregate.⁠[12]
  • Roughly 11% to 15.5% of payroll went to compliance at the smallest community banks across ten years of CSBS surveys, 2015–2024, against 6% to 10% at the largest.⁠[13]
  • 25.0% of community banks' compliance cost went to money laundering rules in CSBS's 2026 survey, second to safety and soundness at 25.9%.⁠[14]
  • About three-fifths of community banks' compliance spending was salaries and benefits in CSBS's 2025 survey.⁠[15]

These figures measure different things in different years and samples, so compare them with care. Where the hours go is in Compliance operations.

How AI coworkers can help

Socratix AI coworkers can take on the gathering. For every LAR row, they pull the evidence from each system, check it against your policies and the source documents, and hand your team a recommendation with the reasoning laid out; for every SAR case, cash report or examiner request, they can do the same. Your team still makes every call — it just stops spending the day assembling the picture.

The clocks above don't stretch when the queue grows. With the gathering done on every item, the same team can work from the full record instead of a sample. Regulators have opened the door: FinCEN's 2026 proposal says institutions that responsibly experiment with innovative technologies won't face added enforcement risk solely for using them.⁠[12]

  1. GatherCan pull the evidence for each SAR case, CTR, LAR row or exam request — transactions, account history, due diligence, prior filings, loan documents — from the systems that hold it, into one case.
  2. AssessCan check the reported data against the source documents and your policies, flag each mismatch with the document it came from, and watch the clocks: CTR and SAR deadlines, HMDA filing dates.
  3. RecommendCan propose the next step with the evidence and a plain-language reason: a draft SAR narrative when one is warranted, or a correction to a LAR field. Your team decides.
  4. LearnCan learn from each decision — your policies, your risk appetite, your team's judgment — and log every step for the examiner.

Compliance FAQ

What is the difference between a CTR and a SAR?

A currency transaction report is required for cash over $10,000, suspicious or not. A suspicious activity report is a judgment about suspicion, for any kind of payment, and it's confidential; if a cash transaction over $10,000 is also suspicious, the bank files both. Cash just under $10,000 doesn't by itself require a SAR. It does when the bank knows, suspects or has reason to suspect the transactions were designed to evade reporting, and they involve or aggregate $5,000 or more.

31 CFR 1010.311 · 1020.320(a)(2)(ii) · SAR FAQs, Oct 9, 2025, Q1⁠[16]⁠[8]⁠[3]

When is HMDA data due?

By March 1 of the year after it's collected: data collected in 2026 are due Monday, March 1, 2027. A deadline that falls on a Saturday or Sunday moves to the Monday, which is why 2025 data were due March 2, 2026. Through the year, each quarter's data go on the register within 30 calendar days after the quarter ends.

12 CFR 1003.5(a)(1), 1003.4(f)⁠[9]

How long must BSA records be kept?

Generally five years, stored so they can be retrieved within a reasonable time. The five years start at different points: from filing for a SAR and its supporting documentation, from the report for a CTR, and from the account's closing for customer identification information. HMDA has its own rule: keep a copy of the loan/application register for at least three years.⁠[2]⁠[3]⁠[17]⁠[9]

Do credit unions follow the same compliance calendar?

Mostly. FinCEN's rules define “bank” to include credit unions, so the same CTR, SAR and recordkeeping rules apply, and credit unions also follow the NCUA's SAR rule. HMDA applies to a credit union that passes Regulation C's coverage tests. The exam cycle differs: the 2026 rule allowing 18 months between exams comes from the OCC, the Federal Reserve and the FDIC, so it doesn't cover credit unions.

31 CFR 1010.100(d)(6) · 12 CFR 748.1(d)⁠[2]⁠[7]⁠[9]⁠[11]

Can AI help with exam preparation?

It can take on the gathering, not the judgment. Before an exam your team assembles the risk assessment, board reports, prior findings, independent testing results, training records and samples of cases and filings. AI coworkers can log every step of each case as the work happens, and pull the evidence for an examiner's request into one file for your team to review. In 2018 the federal banking agencies, FinCEN and the NCUA said pilot programs shouldn't by themselves draw supervisory criticism; expect examiners to look at oversight, testing, and who makes each decision.⁠[18]

Sources

  1. 1.FinCEN, Year in Review for Fiscal Year 2025 · May 2026
  2. 2.eCFR, 31 CFR Part 1010, General Provisions (including 1010.100, 1010.230, 1010.306, 1010.311, 1010.313, 1010.350, 1010.430, 1010.520, 1010.810) · current
  3. 3.eCFR, 31 CFR 1020.320, Reports by banks of suspicious transactions · current
  4. 4.eCFR, 12 CFR 21.11, Suspicious Activity Report (OCC) · current
  5. 5.eCFR, 12 CFR 208.62, Suspicious activity reports (Federal Reserve) · current
  6. 6.eCFR, 12 CFR 353.3, Reports and records (FDIC) · current
  7. 7.eCFR, 12 CFR 748.1, Filing of reports (NCUA; SARs at paragraph (d)) · current
  8. 8.FinCEN, Federal Reserve, FDIC, NCUA and OCC, Frequently Asked Questions Regarding Suspicious Activity Reporting Requirements · Oct 9, 2025
  9. 9.eCFR, 12 CFR Part 1003, Home Mortgage Disclosure (Regulation C), including Appendix B · current
  10. 10.FFIEC and CFPB, Filing Instructions Guide for HMDA Data Collected in 2026 (version 1.0) · Oct 2025
  11. 11.OCC, Federal Reserve and FDIC, Expanded Examination Cycle for Certain Small Insured Depository Institutions and U.S. Branches and Agencies of Foreign Banks, interim final rule, 91 FR 58009 · Sept 14, 2026
  12. 12.FinCEN, Anti-Money Laundering and Countering the Financing of Terrorism Programs, proposed rule, 91 FR 18704 (cost estimates at 18733–34) · Apr 10, 2026
  13. 13.Conference of State Bank Supervisors, Too Small to Scale: What 10 Years of Data Say About Community Bank Compliance Costs (CSBS survey years 2015–2024) · Nov 13, 2025
  14. 14.Conference of State Bank Supervisors, 2026 CSBS Annual Survey of Community Banks (330 banks under $10 billion; self-selected sample, simple averages) · 2026
  15. 15.Conference of State Bank Supervisors, 2025 CSBS Annual Survey of Community Banks (268 banks under $10 billion; simple averages) · 2025
  16. 16.FinCEN, FinCEN Suspicious Activity Reporting (SAR) Filing Instructions, Version 1.0 · Apr 2026
  17. 17.eCFR, 31 CFR Part 1020, Rules for Banks (including 1020.210, 1020.220, 1020.315, 1020.410) · current
  18. 18.Federal Reserve, FDIC, FinCEN, NCUA and OCC, Joint Statement on Innovative Efforts to Combat Money Laundering and Terrorist Financing · Dec 3, 2018

This guide is general information, not legal advice.

Get started

Ready to see what Socratix can do?

Fraud is dynamic. You need systems that adapt, learn, and act in real time — our agents do more than automate workflows, they make intelligent decisions.