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May 21, 2012
Categories: BSA Accounts

BSA E-Filing Reminder; ATM Fee Disclosure Bill Update

Written by Bernadette Clair, Regulatory Compliance Counsel

FinCEN has issued a notice reminding financial institutions that effective July 1, 2012, most Bank Secrecy Act (BSA) reports must be filed electronically.  In the notice, FinCEN reiterates that as of the effective date, institutions must submit most reports electronically unless they have been granted a temporary exemption.

If you need more information on this requirement, our March 7thblog included links to FinCEN’s final rule, along with a few E-filing resources.

FinCEN Webinar.  FinCEN held a webinar earlier this month regarding the technical specifications of the new SAR, CTR and DOEP forms.  This webinar was geared toward IT folks, so be sure to pass this along to anyone at your credit union who fits the bill.

Topics covered in the webinar include:

  • Overview of the E-Filing specifications for FinCEN’s new CTR, SAR, and DOEP.
  • Overview of BSA E-Filing Test site and Testing Process.
  • FAQs about the E-Filing specifications.

The recorded webcast can be viewed here.

Note:  FinCEN will be conducting a future webinar for compliance professionals with BSA-related responsibilities.  The webinar will discuss the E-Filing process for the new CTR and SAR. 

Who do I call with Technical Questions related to E-Filing?  FinCEN provides the number to its BSA E-Filing Help Desk for technology-related questions:  1-866-346-9478.

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ATM Bill Update.  Last Thursday, Sen. Michael Johanns, R-Neb., ranking member of the Senate Banking Subcommittee on Security, International Trade and Finance, introduced bill S. 3204 to end the requirement to display a fee-notice placard on automated teller machines.   Steve blogged about a similar bill, H.R. 4367, last month. 

Both S. 3204 and H.R. 4367 would revise the Electronic Funds Transfer Act by eliminating the placard fee-notice rule. If the legislation is enacted, ATM owners would only be required to provide notices of fees on screen at a point when consumers can still opt to cancel their transactions.

NAFCU is urging credit unions to contact their lawmakers to urge support for S. 3204 and H.R. 4367. Dial 202-224-3121, or use our Take Action tools.

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