Compliance Blog

Written by Bernadette Clair, Regulatory Compliance Counsel

In the spirit of holiday giving, here’s one more present for you…FinCEN has extended its originally proposed deadline for using the new CTR and SAR from June 30, 2012 to March 31, 2013.  The extension is intended to give institutions more time to make the transition to the new reports, and make any necessary internal processing or system changes.

But wait…we’re not out of the woods just yet.  Remember that proposal FinCEN issued to mandate electronic CTR and SAR filing?  That’s still on the table and the proposed deadline remains June 30, 2012.  We blogged about this proposal on September 19th.

Although there will be a short reprieve from mandatory use of the new reports, don’t expect the same for e-filing. Here’s what FinCEN had to say about e-filing in this latest announcement:

“FinCEN expects that the clear benefits associated with the transition to a fully electronic reporting system will support mandating electronic filings of BSA reports as of the proposed date of June 30, 2012. FinCEN will continue to consider the comments received on its proposal, and will follow the normal procedures for concluding the notice process. As reflected in the notice, for those financial institutions unable to meet the proposed electronic filing deadline, FinCEN will consider, based upon certain limited hardship exceptions, specific requests to file the most current paper forms for up to one year past the mandatory electronic filing deadline. Further information on how financial institutions can make such requests will be provided in a future notice.”

Thus, if you’re not yet e-filing your CTRs and SARs, now is the time to start thinking about it.  Also, keep an eye out for more information on the new forms, which FinCEN says it will be making available soon.