Skip to content
BOL Conferences
Thread Options
#1970712 - 10/21/14 12:44 PM SAR & CTR Instructions Revised
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
The current versions of the instructions for these reports are:

SAR: Version 1.3 , September 2014

CTR: Version 1.4 , September 2014

They have removed the demonstration reports from the User Test System so I cannot tell if the reports themselves have been revised.

Would one of you please let us know what the current versions of the reports are on the e-filing system?
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
BSA/AML/CIP/OFAC Forum
#1970717 - 10/21/14 01:11 PM Re: SAR & CTR Instructions Revised Elwood P. Dowd
Cbecotte Offline
Member
Joined: Jun 2009
Posts: 72
Massachusetts
The SAR is v 1.1 and CTR is v 1.2.

Return to Top
#1970930 - 10/21/14 08:15 PM Re: SAR & CTR Instructions Revised Cbecotte
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Thank you. Unchanged...
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#1970988 - 10/22/14 11:49 AM Re: SAR & CTR Instructions Revised Elwood P. Dowd
Pat Patriot Act Offline
Gold Star
Pat Patriot Act
Joined: Apr 2009
Posts: 450
Of course. Add new field values and requirements, but forget to update the actual form itself. Our tax dollars hard at work.
_________________________
CFE, CAMS

Return to Top
#1970992 - 10/22/14 12:30 PM Re: SAR & CTR Instructions Revised Elwood P. Dowd
CarolynA Offline
New Poster
Joined: Sep 2013
Posts: 19
I still see version 1.2 of the CTR and SAR instructions on the FinCEN website. What am I doing wrong?

Return to Top
#1972033 - 10/25/14 06:09 PM Re: SAR & CTR Instructions Revised CarolynA
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
I don't think you're doing anything wrong. This page on the FinCEN web site is suffering from a lack of maintenance; e.g. it contains the older versions of the instructions, still refers to them as "forms" (including their form numbers) rather than "reports" etc.

The User Test System contains the current versions of the instructions. The current "reports" have also been restored.

P.S. FYI, the User Test System prefers Internet Explorer; I cannot get the reports to open using Chrome.
Last edited by Ken_Pegasus; 10/27/14 04:30 PM. Reason: Add P.S.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#1973910 - 11/04/14 02:38 PM Re: SAR & CTR Instructions Revised Elwood P. Dowd
WonderWoman Offline
Diamond Poster
WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
I'm noticing some discrepancies.

CTR revisions:

Updates to Record Layouts

• Person Involved in Transaction(s) (4A) Record:
o Replaced “Access the NAICS Code list from the BSA E-Filing Web Site” with “Use ONLY the NAICS Codes from the NAICS Code list on the BSA E-Filing Web Site Access the NAICS Code list from the BSA E-Filing Web Site (http://bsaefiling.fincen.treas.gov/main.html). Use of NAICS Codes not on this list is prohibited ” in the Description and Remarks for NAICS Code (Item 9).

Updates to Attachment C – Electronic Filing Instructions

Item Instructions (9a. NAICS Code):
o Replaced “Access the list of NAICS Codes authorized for use in the FinCEN CTR on the BSA E-Filing Web Site” with “Batch filers should only enter codes from the list of NAICS Codes authorized for use in the FinCEN CTR and located on the BSA E-Filing Web Site (http://bsaefiling.fincen.treas.gov/main.html) or from the NAICS list provided at https://www.census.gov/cgi-bin/sssd/naics/naicsrch?chart=2012.”


So wait ... which one do we use now?
Last edited by WonderWoman; 11/04/14 04:50 PM.
_________________________
My opinions are my own, and not that of my employer.

Return to Top
#1974199 - 11/05/14 03:11 PM Re: SAR & CTR Instructions Revised Elwood P. Dowd
Pat Patriot Act Offline
Gold Star
Pat Patriot Act
Joined: Apr 2009
Posts: 450
BEGINS RANT:

FinCEN really needs to focus on maintaining a consistent message on the details of how things should be done. Without getting into specifics, there are plenty of topics among the forms, instructions, and FAQs where they seem to contradict themselves or have misleading information.

Some of my favorites include:

The FAQ instructing users to include in Part III, under the heading "Financial Institution Where Activity Occurred" the branch of suspicious activity if it's not the home office and it's the only branch involved, while having the "Branch where activity occurred information" then require the user to check off "If no branch activity involved, check this box" to not have to enter in the same branch twice.

The form Item 27 being labeled "Date or date range of suspicious activity for this report" while indicating in the instructions "If "Continuing activity report" is selected as the filing type, enter only the date range covered by this SAR", which some examiners are reportedly interpreting as meaning Item 27 on a CAR equals the "period reviewed" while others interpret as Item 27 on a CAR equaling the date range of suspicious activity within the date range of the review of the CAR.

The whole "90-Day Review" debacle. First we file every 90 days, then every 120, then every 90 again, then every 120 - but it can only be on 90 days worth of activity (better not be 91!!!). This is is well documented, so I won't go any further...

Then one person says a FinCEN Rep. said this, while another said FinCEN Rep. said that. And as always, both FinCEN reps refused to put it in writing.

END RANT

I'm sure there are more examples...

Moderators: Perhaps a "sticky" thread is needed to document all of the "inconsistencies."
_________________________
CFE, CAMS

Return to Top
#1974408 - 11/05/14 06:29 PM Re: SAR & CTR Instructions Revised Elwood P. Dowd
BSAAnonymous Offline
100 Club
Joined: Feb 2012
Posts: 165
Would they criticize you for not using the most updated version? I am not seeing material changes between the form.

Return to Top

Moderator:  Andy_Z