Tell us
what you think
Our Sponsors
 |
Our Sponsors
|
Question & Answer
The normal procedure on the Q & A page is for our subscribers to ask the questions and the experts to answer them. This issue we have a reverse procedure - seems only fair!
When I called Charles Klingman from FinCEN for the answer to yet another question on CTR filing and exemptions, he asked me some questions about why more financial institutions are not using the Phase II exemption as much as anticipated. I gave him my opinion, but that's not the same as getting the reasons from you, our subscribers. Here are the questions he asked me, which we're passing along for your help. Please let me (or Charles) hear from you. FinCen has always been ready to help us - we'd like for the BANKERS' HOTLINE to be able to help them!
Question 1: There seems to be a significant group of banks that are not using the new exemption system for CTRs.
What issues or concerns discourage or impede a bank's ability to use these regulations?
Is there a concern about the lack of clarity of their application to 'transaction accounts'?
Is there a concern about examination guidelines for these regulations?
Is there a concern about the annual duty to monitor the transactions exempted?
Is there a concern about the biennial certification?
Are there other unrelated issues, such as Y2K, etc., that make it undesirable to use the new exemption rules?
Question 2: With respect to operational concerns regarding the BSA, what are the BSA sections that are the least clear as to what FinCEN expects? Which specific area would banks most desire greater clarity in the shorter-term from FinCEN? For example, the exemption rules, CTR reporting rules, aggregation of CTRs, wire rules, SAR rules, CMIRs, monetary instrument purchase recordkeeping, etc., etc.
Any help or ideas you can give would be greatly appreciated.
Thank you.
Charles Klingman
Responses can be phoned, faxed, emailed, written - however you'd like to communicate - either directly to FinCEN or to this Editor. BANKERS' HOTLINE would really appreciate any help you can give to Charles in his efforts. He has always been most cooperative in answering our questions and problems, and we'd like to reciprocate.
Bankers' Hotline
P.O. Box 918
Brookhaven, PA 19015
Phone: (610) 874-5522
FAX: (610) 872-6231
Email: hurst@bankersonline.com
FinCEN - Charles Klingman
2070 Chain Bridge Road, Ste 200
Vienna, VA 22182-2536
Phone: (703) 905-3602
FAX: (703) 905-3885
RegComments@fincen.treas.gov
Copyright © 1999 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 9, No. 6, 7/99
Rate This Article
Current Rating For the Feature:
| Total Ratings for this Feature: 0 |
|