Compliance Blog

Written by Bernadette Clair, Regulatory Compliance Counsel

FinCEN has issued a final rule requiring the electronic filing of most Bank Secrecy Act (BSA) reports, including Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs).  In its press release, FinCEN indicates this will “improve efficiency, reduce government and industry costs, and enhance the ability of investigators, analysts, and examiners to gain better and more timely access to important financial information.” We previously blogged about FinCEN’s push towards mandatory e-filing on September 19^th and December 27^th.

Effective Date.  The rule mandates electronic filing effective July 1, 2012.

Are there any exemptions?  FinCEN will grant a very limited number of temporary exemptions to institutions that follow the certain procedures and that demonstrate a substantial hardship in meeting the July 1, 2012, requirement.   Small credit unions lacking internet connectivity or large institutions undergoing major system conversions to enable batch and computer-to-computer CTR filing may want to check these out.

Deadline for exemption requests.  Requests must be submitted directly to FinCEN by March 26, 2012, using the procedures outlined in this notice.  In the notice, FinCEN includes a template that institutions may use.

Where do I start if I don’t e-file yet?  FinCEN maintains a website dedicated to BSA e-filing.  Here, you can take a tour of the BSA e-filing system, read FAQs, and sign up for e-filing.  Getting Started with BSA E-Filing takes you step-by-step through the e-filing enrollment process and is a great place to start when you’re ready to sign up.