During an internal audit, I would like to check whether my bank has received and processed all 314(a) lists before the FinCEN specified deadline. My bank retains the request lists in a file, however, if one is not inserted into that file, I wouldn't know that my bank missed it. Is there a comprehensive listing of all FinCEN 314(a)request list in order to verify that my bank has received and processed all of them?

The FinCEN 314(a) requests come out bi-weekly. If your bank retains the request lists in a file and they have a date, I would make sure each request is roughly two weeks apart. If they don't have dates, whats the use of keeping a file. However, if this does not work, try contacting someone at FinCEN.

Before you go to far, our regulator (FDIC) actually mandated that we not keep the search requests in any form (physical and electronic). Which meant a fair bit of shreading and deleting for me. Luckily I also used this handy checklist provided by none other than BOL. I modified it to match our department structure and search methods, but it works nicely.

Though unhappy with our retention of the requests they actually asked for a blank copy of the checklist so they could use it as an example to show other Banks.

We use a tracking list built in excel. We notate the tracking number, date received, date searched, time searched, Y/N on any match, and if there was what type of action was taken.

Our regulator suggested it and has worked really well.

The regulators want to see that you are keeping track of the tracking number. And they also want to ensure that the people you are sending the information to (if any) realize the strict confidentiality of the information and that all information used to do the search is shreaded.

We too have been keeping our 314a requests forever thinking there was a 5 year retention on these. So am I understanding this correctly that we should shred them, delete all e-mails, and just keep the BOL form that we complete with the tracking #'s on?

dare2dream has it right. The examiners are looking for something with the appropriate date and the tracking numbers on the requests. That's about it. So yes, you should shread the request lists and delete electronic copies. Just make sure you keep the tracking forms you've been using--those do have a 5 year retention I believe.

Just got done listening to the FDIC Chicago Region's conference call on BSA/CIP/AML this morning and this question was address. You are correct in that you do not need to keep the actual lists themselves, but be able to prove that they were checked in the appropriate time frames and notate action(s) taken on hits. Addtionally, Richard M Giloffo (BSA Case Manager FDIC Chicago) indicated that you may hold onto about 6 weeks worth of the FinCen lists before destroying, but do hold onto your tracking forms.

If you can get the person who has access to FinCen's website you'll be able to tell what hasn't been opened. I know because I had the flu on a Tuesday when it was due and forgot about it again until the next Tuesday when it was time to look and both of them were listed as not opened. Maybe this will help resolve your issue.

I use a software program called WatchDog by Attus Technologies. I have found the program to be very user friendly and I am able to print off a statistics report every time I do my scrubs. This makes for easy record keeping and examiners were completely satisfied.