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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.
CA PRIVACY NOTICES STILL REQUIRED
updated 02/02/16 08:35 AM
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The FAST Act made changes to federal annual privacy notice requirements. However, it did not change California privacy notification requirements, which are applicable to all financial institutions doing business in California. California state annual privacy notifications are still required, depending on what information is shared and with whom.
CUSOs TO REGISTER WITH NCUA REGISTRY
updated 01/26/16 10:07 AM
NCUA Hosts Webinar on New System
In a letter sent to credit unions, credit union service organizations (CUSO) have 60 days to register with the National Credit Union Administration’s (NCUA) CUSO Registry, the new online system for CUSOs to report their operational and financial information directly to the agency. The registration period begins Feb. 1 and ends March 31.