Compliance Blog

Written by Bernadette Clair, Regulatory Compliance Counsel

Even if you already e-file, don’t let this one slip past you.  Under current BSA e-filing specifications, CTRs filed electronically within 25 calendar days are considered timely.  This is from FinCEN’s E-Filing FAQs: 

“Must CTRs (Currency Transaction Reports) be filed within 15 days after the transaction date (as with paper filings) or within 25 days (as for batch filings)?

In accordance with BSA E-Filing electronic filing requirements, CTRs will be considered on time if received by FinCEN no more than 25 calendar days after the date of the transaction.”  (emphasis in original)

Well, no more!  FinCEN’s final rule states that “FinCEN has consistently maintained a regulatory requirement that CTRs be filed within 15 days.”  FinCEN indicates that the 25 calendar day specification originally started to accommodate institutions that filed magnetic media files on a fixed schedule, and that the practice carried over to e-filing.

When does this change take place?  The FinCEN 25-day compliance period will temporarily remain in the e-filing specifications until March 31, 2013.  After that, the specifications return to the regulatory requirement of 15 days.

To avoid any unpleasant surprises come March 31, 2013, this might be a good time to review internal procedures and systems for any necessary adjustments to ensure timely CTR filings.