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#1630143 - 11/18/11 02:04 PM BSA Electronic Filing Proposal
rlcarey Offline
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I didn't really read the proposal to make electronic filing mandatory by June 2012. I just thought it was going to business as usual, just using the current electronic formats. You can imagine my surprise when I read the ABA comment letter on the issue. I would suggest that every bank pull out your pen and paper and get on the band wagon and submit comment letters:

https://www.aba.com/NR/rdonlyres/F5F23FB...file2011Nov.pdf
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#1630148 - 11/18/11 02:17 PM Re: BSA Electronic Filing Proposal rlcarey
Elwood P. Dowd Offline
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In the same boat as Randy...this is more than just a bunch of new forms. The ABA has performed a service here.
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#1630159 - 11/18/11 02:31 PM Re: BSA Electronic Filing Proposal Elwood P. Dowd
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Am I understanding this correctly? FinCEN, under the nonsense claim of mandatory e-filing is trying to substantially alter both the CTR ann SAR forms...?

Wow.
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#1630168 - 11/18/11 02:43 PM Re: BSA Electronic Filing Proposal ACBbank
Elwood P. Dowd Offline
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The forms revisions are more under the heading of "IT modernization," something that is long past due and for which some groundwork was laid several months ago when they put the new concepts for the forms out for comment. However, by digging through the entrails of the new technical specifications the ABA has noted several things that are substantive changes.
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#1630175 - 11/18/11 02:51 PM Re: BSA Electronic Filing Proposal Elwood P. Dowd
ACBbank Online
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It looked like the "IT modernization" is going to require a lot more work on behalf of banks. For once, I actually agree with the ABA. It will be interesting to see how this plays out.
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#1630182 - 11/18/11 03:01 PM Re: BSA Electronic Filing Proposal ACBbank
J2C Offline
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Big Brother knows and that's a...
I sit on the monthly ABA Anti-Money Laundering calls (available to those that are ABA member banks) and they talked about this last month and really encouraged us all to submit comments to them based on the proposal. They had indicated they would be making some comments to this. I am glad to see they did.

The proposal has gone a bit overboard and once again many FI could be blindsided by these changes if it gets through.
Last edited by jennyfromthebloc; 11/18/11 03:09 PM.
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#1630265 - 11/18/11 04:18 PM Re: BSA Electronic Filing Proposal J2C
justfriendlyme Offline
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wisconsin, USA
I will have to first admit that I have not read this yet, but I did attend a seminar recently that indicated that the E-filing system was going to revise the forms so that all types of CTR and SAR filing entities would be using the same form (so no separate or special forms for casinos etc).

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#1630269 - 11/18/11 04:25 PM Re: BSA Electronic Filing Proposal justfriendlyme
Elwood P. Dowd Offline
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They will not be using the same form. In essence, when you log on you will identify your status; e.g. depositary institution. Then, your form will appear on the screen.
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#1630338 - 11/18/11 05:24 PM Re: BSA Electronic Filing Proposal Elwood P. Dowd
J2C Offline
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Big Brother knows and that's a...
To Randy's first comment....it's time we start writing letters.
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#1630342 - 11/18/11 05:28 PM Re: BSA Electronic Filing Proposal J2C
Kathleen O. Blanchard Offline

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It is an amazing amount of changes.
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#1630372 - 11/18/11 06:08 PM Re: BSA Electronic Filing Proposal Kathleen O. Blanchard
E.E.G.B Offline
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I can't believe FinCEN wrote that it wouldn't require much change / burden on the part of the financial institutions.
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