Compliance Blog

Written by Steve Van Beek

FinCEN has issued a proposed rule that would require e-filing of currency transaction reports (CTRs) and suspicious activity reports (SARs).  If finalized, this mandatory e-filing would begin June 30, 2012.  

FinCEN indicates that 84 percent of BSA reports are currently submitted electronically.

Here is what FinCEN indicated in their "filer impact" section for depository institutions:

"a. Depository institutions: Based on information available we believe this change in filing procedures will have minimal impact on depository institutions.  All depository institutions are currently required to file quarterly call or thrift financial reports with their regulator electronically through a Web-based portal provided by the appropriate federal regulator. This same electronic connectivity may be used to file BSA reports with FinCEN by logging in to the BSA E-Filing System Web-based portal."(emphasis added).

During the comment periods are when battles over "regulatory burden" can have the biggest impact.  If this change to e-filing will be "more than minimal" for your credit union - now is the time to let FinCEN know.

NAFCU's Regulatory Affairs team will be drafting a Regulatory Alert on this proposal as well as submitting a comment letter to FinCEN.  The more detailed your comments on time, staff hours, training and other costs associated with moving to e-filing the better.  Of course, if the move is truly minimal those comments are useful as well.  

The full proposed rule is here (and will be published in the Federal Register soon).  Comments will be due to FinCEN 60 days after the rule is published.  

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This week is NAFCU's Congressional Caucus in Washington D.C.  Here is a photo of one of NAFCU's lobbyists, Chad Adams, and his beautiful daughter with Majority Leader John Boehner.

 
 And, yes, that is an OSU jacket...