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FinCEN's new Suspicious Activity Reports (SAR), Currency Transaction Reports (CTR), Registration of Money Services Business reports (RMSB), and Designation of Exempt Person Reports (DOEP) have been available for use through the E-Filing System since March 29, 2012, with adoption of the new reports by credit unions and other institutions increasing.
The BSA E-Filing System will continue to accept submissions of the legacy versions of the SAR, CTR, DOEP, and RMSB only until March 31. The FinCEN BSA E-Filing User Test System website has been updated to allow for testing of all the reports now available for E-Filing.
Last year the Financial Crimes Enforcement Network (FinCEN) issued a final notice requiring the electronic filing of most Bank Secrecy Act (BSA) reports by July 1, 2012. Specifically, this action mandates the electronic submission of SAR, CTR, RMSB, and DOEP reports. These reports are collectively referred to as "mandated reports." With very limited exception, FinCEN considers financial institutions filing mandated reports in paper format to be noncompliant with the electronic filing mandate.
Civil Money Penalties
Financial institutions that continue to file mandated reports in paper format will fail to meet BSA reporting requirements and may be subject to civil money penalties. After March 31, FinCEN may reject any mandated reports filed in paper format and return them to the filing institution.
For more information about BSA E-Filing, please review the E-Filing Section on FinCEN's website. Any general questions regarding this notice should be directed to the FinCEN Regulatory Helpline at 1-800-949-2732. For other technology-related questions specific to E-Filing, call the BSA E-Filing Help desk at 1-866-346-9478.
UNCLAIMED PROPERTY HANDBOOK
updated 04/26/16 07:15 AM
Plus, Title XIV Mortgage Updates
California State Controller's Office has issued an updated Unclaimed Property Holder Handbook with changes to reflect:
CREDIT CARD SUBMISSION GUIDANCE
updated 04/18/16 12:02 PM
Plus, Compliance Advice Webinar
The Consumer Financial Protection Bureau (CFPB) has issued guidance for credit card issuers with simplified instructions for making the required submissions under Regulation Z. Last year, the CFPB temporarily suspended this rule until April 30, 2016. Issuers have to submit credit card agreements to the Bureau by May 2, 2016, and quarterly thereafter.