I have just seen Michigan enrolled house bill 4580 (amending PA 117) that apparently changes the requirement to send BSA "transaction" reports to the state police so that we only have to send SARs, not CTRs - effective immediately. Am I interpreting this correctly? Do we use the same mailing address?

I'd say you've got it right. It looks like this Act (PA 117 of 2003) limits the state-mandated reporting to just SARs; expands the methods of reporting to anything acceptable by the state police; and preserves the civil liability safe harbor.

I know the MBA was pushing for this - next Compliance Committee meeting is Sept. 10, so I'd expect to hear more at that time. I haven't seen any bulletins about it, but I'm less than 2 weeks at a new position...

Here's a link for the interested parties: PA 117 of 2003

Thanks for the link, I hadn't heard anything official on this. I am wondering if they changed the mailing address though, because I just had an envelope returned that was mailed to 2911 Eyde Pkwy., Suite 130, East Lansing, MI 48823. Have an e-mail into the MBA for an update.

Does this law apply ONLY to banks chartered in the state of Michigan? Or does it apply to banks chartered elsewhere that have branches in Michigan, and consequently have suspicious activity located there?

Having only worked in state-chartered shops, I can't answer with any confidence. However, I believe it only applies to state member or non-member banks.

This is a good question for counsel. Or, you might try the Michigan Bankers Association at 517-485-3600.

An update:

New Mich. State Police SAR address is

Michigan Dept. of State Police
Attn: Intelligence Unit
4000 Collins Rd.
Annex Building
Lansing, MI 48910

This applies to state chartered banks only. Deadline for filing is 24 hours after filing with FinCEN.