FinCEN announced that the deadline for financial institutions to utilize FinCEN's new Currency Transaction Report (CTR) and Suspicious Activity Report (SAR) for reporting purposes will be extended to March 31, 2013.


FinCEN still thinks it has a valid case for mandating e-filing by June 30, 2012, but it extended the date for use of the new, expanded, file formats for CTRs and SARs in response to industry complaints that the original 6/30/12 date would not provide enough time for implementation and testing.

As the forms are not available and the industry hasn't even seen prototypes, it seems appropriate that their required use would be delayed...

I was thinking the same thing...what do the new forms even look like?!!?

Well, IMHO since mandatory e-filing will be required, there will probably not be any forms. You would have to refer to the new proposed e-filing specification guidelines.

I agree. No "form" in the traditional sense. But oh the content!

Specs for the electronic "form":

http://www.fincen.gov/news_room/nr/html/20110902.html

I love how the changed the web-site already and have all the current forms under "Legacy Forms".

There will a "form" to the extent e-filers currently have to fill out a form, albeit electronic; I did not suggest they would be available on paper. Although the original requests for comment made it clear that paper filing would still be possible with the revised CTR, SAR, and DOEP, subsequent decisions appear to make that unlikely.

If everyone wants to call them "dynamic information collection devices," as some of the folks I've talked to at FinCEN do, knock yourself out. I'm still going to call them "forms."

Well, the virtual form is already published. Each required data field is described in these documents for both the new CTR and SAR:

http://bsaefiling.fincen.treas.gov/news/FinCENCTRElectronicFilingRequirements.pdf

http://bsaefiling.fincen.treas.gov/news/FinCENSARElectronicFilingRequirements.pdf

Thanks!

The proposal also mentions reducing the e-filing deadline from 25 days to 15 days. Is this effective in March 2013 or June 2012?

The new filing deadline goes with the new form, so when you start using the new form, you will have the new deadline.

Everything seems to discuss batch filing standards. If we will be e-filing discrete forms, where do we find information on when the new format will be required?

FinCEN announcement. In terms of when use of the form is required, they make no distinction between batch and discrete filing.