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Important Notice for Paper CTR & SAR Filers

Important Notice for Paper CTR & SAR Filers – Mandatory Electronic Filing:

FinCEN submitted a notice to the Federal Register regarding the electronic filing of Bank Secrecy Act (BSA) reports.  Financial institutions must electronically file (e-file) all reports by July 1, 2012.  FinCEN previously announced that it was extending the deadline for the mandatory use of the new electronic CTR and electronic SAR to March 31, 2013.  This is not a blanket exemption for paper filers. In addition, FinCEN announced:

  • A general exemption from mandatory electronic filing of the Report of Foreign Bank and Financial Accounts (FBAR) until July 1, 2013; and
  • A process by which institutions may apply for a limited duration hardship exemption from the requirement to file reports electronically beginning July 1, 2012.

Note to Paper filers:

FinCEN announced that no paper copies of the CTR or SAR form will be accepted after July 1, 2012 unless a temporary exemption is requested by March 26, 2012.

FinCEN will grant a very limited number of temporary exemptions to institutions that follow the agency's procedures and that demonstrate a substantial hardship in meeting the July 1, 2012 requirement:

  • Small credit unions (and money services businesses) lacking internet connectivity:
  • Major system conversion to enable batch and computer-to-computer CTR filing:
  • Other extraordinary circumstances: FinCEN will consider requests for temporary hardship exemptions based upon other extraordinary circumstances, but FinCEN does not expect to grant a significant number of such exemptions. Financial institutions requesting such an exemption must certify that the exemption request is not solely due to an institution’s need to make changes to its internal review processes, training, or revisions to its anti-money laundering (AML) program. FinCEN may request further information or documentation from the institution, and may contact the institution’s primary regulator with respect to information received. Generally, FinCEN does not expect to grant such exemptions beyond March 31, 2013.

Instructions for submitting a request for temporary exemption are detailed in the FinCEN notice, available here.  FinCEN has provided a template that institutions may use to make these requests and has posted a recorded instructional presentation to assist filers with the new requirements.  Requests must be submitted no later than March 26, 2012; FinCEN plans to notify the requesting institution of its decision no later than April 25, 2012.

Click here for the press release “FinCEN reports going paperless.”

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