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It looks like FinCEN is preparing to save some trees. FinCEN has proposed a rule to make the electronic filing of reports required under the Bank Secrecy Act mandatory. FinCEN stated that the move will improve efficiency, reduce costs, and enhance the ability of its investigators, analysts, and examiners to review the reports. The proposed rule is open for comments and if implemented, would require e-filing as of June 30, 2012.
FinCEN indicates that 84 percent of BSA reports are already submitted electronically. So, if you have not startedfiling your reports electronically, now is a great time to start. Here are a few things to remember:
1) Electronic filing can help reduce the amount of errors on CTRs, as the report cannot be submitted without certain fields being completed. It also saves your credit union a stamp! However, be mindful if you leave section B blank and forget to check a box to indicate your reason for leaving the section blank, the site will allow you to submit the report (from my experience).
2) BSA officers should ensure that they are reviewing the CTRs prior to filing. I recommend that the BSA officer and a back-up are the only individual’s with log-ins to the website.
3) Print copies of the filed CTR for your records and to ensure they are readily available for your examiners and auditors.
4) Remember to round your reported amounts to the next dollar amount. I blogged on this topic almost a year ago to the day. Check it out here.
I realize for some smaller credit unions that this may be a bit of a headache, but I think in the long run this will be a much easier and efficient way to ensure your CTRs are filed appropriately. However, the struggling postal service may think differently.
Have a good week.
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