Ok, so I'm really confused. On FinCEN's website the CTR and SAR forms are dated March 2011. The forms on their e-filing website are still the older ones. Which ones are we supposed to be using? Ugh...why do they make something that seems so simple so difficult?? Forget it, no need to answer that. :-)

You can use the legacy forms until March 2013. I know Ken is doing an upcoming webinar on the new forms that might be a interest to you. It is going to take substantial programing and training to complete the new forms correctly.

The notice that they were extending implementation of the new forms until 2013 explains that the existing forms will be used until then, but they do expect banks to begin to efile or request a hardship exception from FINCEN is they feel they cannot do so by June 2012. Procedures for requesting a hardship exception will be issued prior to June.

Great, thanks for the explanation. We have been efiling for several years so that's good. Maybe by 3/2013 I'll have moved out of BSA on to other things. lol!