If you have not already registered to electronically file BSA reports, now would be the time to do so. FinCEN recently approved its final rule mandating the electronic filing of reports related to BSA. Here is the low down:
- Electronic filing of BSA reports is mandatory on July 1, 2012 (with the exception of the CMIR form).
- FinCEN announced a temporary exemption for mandatory electronic filing of the Report of Foreign Bank and Financial Accounts (FBAR) until July 1, 2013. However, financial institutions are urged to take advantage of filing electronically.
- FinCEN has stated that very few extensions will be issued for extraordinary circumstances; however, the deadline to apply for an extension is March 26, 2012. FinCEN has provided a notice outlining how to request an extension and indicates that the deadline to file a request is March 31, 2013.
- FinCEN clarified that all CTRs must be filed within 15 days of the transaction.
FinCEN also updated the BSA E-Filing System’s web site to allow financial institutions to test submissions of batch and computer-to-computer filings of FinCEN’s new Currency Transaction Report (CTR) and Suspicious Activity Report (SAR).
Still need to sign up for e-filing? Click here. FinCEN also provides a helpful tour of the e-filing system and explains a few of the many benefits that it provides, along with instructions on how to get started.