I keep a log of the 314 a request that include the date received, tracking numbers, if there was a match or not, and the initial of the employee doing the check.
we just recently had auditors doing the internal bsa audit for us and they found that some of my tracking numbers did not match the ones reported by FinCEN on a couple of days.
I've checked and rechecked our system ( we use Bridger) and can't find how the tracking numbers got so messed up.
Has anyone else seen this happen?
I'm about to call FinCEN but was wondering if I am the only one with this problem.

Auditors or examiners? If they are auditors, how do they have access to the tracking numbers?

It was auditors. they got a copy of the tracking number list that FinCEN has on their website somehow. That's what they used to compare.

Hmmm, if they did not get the list from you make certain they are aware that not every bank gets the same list.

They should not have access to anything on the 314(a) website. Something is fishy with this finding/claim.

Ken, could you please explain your statement that not every bank gets the same list?

If the LEA has an idea where one of their "persons of interest" is, they only send the name to that region of the country rather than nationwide. I did not know that was the practice until I heard a FinCEN official talk about a bank holding company that used the list sent to one of its banks for all of its banks. You're not supposed to do that.

Since Florida Lilly did not give her auditors the list, my assumption is they are using information they got from a different client. It may or may not match and she will not be able to figure out what the problem is without calling FinCEN.

Interesting...

I did not give them the list and so I assumed they got it from another client. I just spoke with FinCEN and found out that anyone can go into their public website at fincen.gov and obtain a list of the tracking numbers. Why would they have that in a public website is very puzzling to me....
I just don't know why they are getting so hung up on the tracking numbers not matching but I will make sure that from now on I double check them before the auditors get here......

I, too in fact had auditors that wanted to verify the 314a tracking numbers with my records. I had the email notifications and the search verifications from the FinCEN website, but no where on these is any kind of tracking number. The only time I could find a case or tracking number was when there was a special request.

If anyone knows where on the 314a site you can find the case number each time, the information would be appreciated. Thanks!

For every search, I used to complete a worksheet that included the tracking numbers but replaced it with FinCEN's "314(a) Search Self-Verification" when that feature became available. The examiners have never questioned that process. If they wanted the tracking numbers retained, wouldn't FinCEN include them on that verification?

I found it on www.fincen.gov it's under the Law Endorcement Information Sharing with the Financial Industry report. It lists the dates, case numbers and the number of persons of interest reported.
Thank you for taking the time to respond. It is very muchreciated!!!

But then again, not all banks may received them all. I would go with keeping copies of the self-certification and call it good.

I have no idea either. I'm not saying its an inadvertent disclosure, I just don't know what the purpose in publishing it would be.

I agree with rlcarey, the self-certification as described in detail in the private portion of the web site should be sufficient proof without the tracking numbers. If my auditor (even Mr. Carey, himself) insisted on some supplemental "requirement" that reflected only his personal opinion then I would conclude that he was more interested in finding something to write about than he was in keeping me on the straight and narrow path.

I should note that I've seen field examiners make the same criticism and, worse yet, that I have seen auditors pick up on and regurgitate the foibles of field examiners in their area as if they represented the gospel.

I check the self-certification and check that the bank is checking the right accounts and responding timely. That's it. There is no indication anywhere what those case numbers would be used for or why they are published. It seems like a "gotcha" of no value.

I was told in August 2010 by a FinCEN Helpline associate that "Every bank in the US gets the same lists." I asked FinCEN about the lists after an FDIC examiner told me he had attended a seminar where a FinCEN official said that different lists may go to banks in different regions of the country. I was quite surprised to hear this, so I called FinCEN immediately and got the above response. I've felt comfortable with the response until today when reading this thread. It appears the FinCEN Official and the FinCEN Helpliner have differing opinions. Quess I'll be calling FinCEN back.

It's under the section where you find the case and numbers and such. they practically give the same information that is found on the website a banker would see. the date, case number and number of hits.

I am a bit confused by all of this since FinCEN does not send out the lists; the banks sign into the Web site and download the lists that are posted. If the info about different lists is true it means that FinCEN has a way to bring the bank to a different screen depending upon where the bank is located. Can this be true?

I think all Banks get the same list. I always have name and locations from the West Coast and I'm in New England so it's not regionalized.

The auditors could have obtained the following list from FinCEN's website:

http://www.fincen.gov/statutes_regs/patriot/pdf/leinfosharing.pdf

The 2 dates I checked matched my list of tracking numbers.

I never had a problem before until I check the dates of 5/18/10 and 6/1/10.

As long as the bank is going in to the FINCEN database and checking properly what is in there for them, what do the auditors expect the bank to do?

We aren't auditing FINCEN.

I agree Kathleen. I've decided not to keep the tracking numbers on my logs anymore. Instead I am going to do the self verification that FINCEN provides and print out the result of that.

I only keep the self verification sheet. I show this to the examiner each time - no problems.