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#1239462 - 08/26/09 03:43 PM Outdated info on FINCEN site
P*Q Offline

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P*Q
Joined: May 2001
Posts: 8,458
Somewhere
Anyone notice that the codified BSA regulations on Fincen's website are outdated? I was looking at the currency transaction section to look up exemption info and it still had the old info (account for at least 12 months, more than 8 transactions, biennial renewals for phase 2). Couldn't believe it still had the old info, not good!
Last edited by Pizza Queen; 08/26/09 03:44 PM.
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#1239484 - 08/26/09 03:58 PM Re: Outdated info on FINCEN site P*Q
ACBbank Offline
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New York City
As with most federal govt. employees, FinCen moves at their own pace.
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#1239489 - 08/26/09 04:00 PM Re: Outdated info on FINCEN site ACBbank
P*Q Offline

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P*Q
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Somewhere
It's crazy!!! If someone was new to BSA and looking for guidance on BSA, Fincen would most likely one of the first places they would look. We're going on 9 months now, you'd think they'd update regulations area more frequently!

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#1239520 - 08/26/09 04:21 PM Re: Outdated info on FINCEN site P*Q
P*Q Offline

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Here is my question, we have a customer that we exempted last year. It's time for thier annual review (phase II) and I noticed that haven't had cash trans. over $10,000 in cash over the last 6 months, other than one day. So, I don't belive they are still eligible. Do I need to file a revocation still? If so, on the DOEP? I couldn't find my answer.

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#1239528 - 08/26/09 04:29 PM Re: Outdated info on FINCEN site P*Q
Kelsey D Offline
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Joined: Aug 2006
Posts: 516
Ohio
You are not required to report a revocation.

Have you considered extending the timeframe of your review to the past 12 months? Your customer may have only had one reportable transaction in the past 6 months, but if you look at the past 12 months, they may have met the threshold of five reportable transactions to remain eligible.
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#1239545 - 08/26/09 04:41 PM Re: Outdated info on FINCEN site Kelsey D
Retread Offline
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Retread
Joined: Oct 2003
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Southeast
Sometimes you just cannot trust FinCEN. If you want an
up-to-date version of 31 CFR 103, go here

http://tinyurl.com/nsxuvr
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#1239562 - 08/26/09 04:54 PM Re: Outdated info on FINCEN site Retread
John Burnett Offline
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Joined: Oct 2000
Posts: 39,697
Cape Cod
FinCEN's link is to the officially codified version of the regulation, which is was last updated in July, 2008. The e-CFR version, linked by Retread, is current.

Unfortunately, linking to the official, codified regulation isn't much help. Can you even imagine looking at the official codified version of Regulation Z for current information?
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