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#1724701 - 07/30/12 01:26 PM Discrete Filing - delays?
Compli(cated) Offline
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Joined: Mar 2011
Posts: 185
Wisconsin
We are in the process of installing BSA software and, in the meantime, had to go the discreet filing route.

I am the BSA Officer here, but the actual filing is to be done by the Asst. BSA Officer. The Asst. is telling me that all the SARs and CTRs have been timely filed but I am not seeing them all under the "Filing-Track Organization Status" tab on FinCEN's website. I am the supervisory user for the institution so it is not an access restriction (also, I can see a few that were filed during the first days of July).

I know FinCEN has acknowledged some delays and technical issues, but based on their latest release, they have cleared out the backlog. Is anyone else having a similar experience or do I need to look at this as a "personnel issue"?
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#1724750 - 07/30/12 02:32 PM Re: Discrete Filing - delays? Compli(cated)
Doug Hendrickson Offline
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Doug Hendrickson
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I have never had a problem viewing all of the SARs and CTRs filed, regardless of who filed them, using the Organization Status function. You most likely are already aware that there is a drop-down box for the time period you want to see and that if the volume is over a certain limit you have to click to get the additional pages.
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#1724788 - 07/30/12 03:04 PM Re: Discrete Filing - delays? Compli(cated)
Compli(cated) Offline
100 Club
Joined: Mar 2011
Posts: 185
Wisconsin
Thanks for the reply Doug. I am aware of the timefrme drop-downs, those do not seem to be the problem either...I didn't want to overreact, but it's seeming more and more appropriate now.
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#1724897 - 07/30/12 06:45 PM Re: Discrete Filing - delays? Compli(cated)
Indy Banker Offline
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Did you receive an acknowledgement response and an acknowledgement e-mail from FinCEN after each discrete form was filed? If not, chances are they may not have gone through.

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#1724910 - 07/30/12 07:04 PM Re: Discrete Filing - delays? Compli(cated)
Compli(cated) Offline
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Joined: Mar 2011
Posts: 185
Wisconsin
Are you receiving those as a supervisory user even if another person does the actual filing? My understanding was that the person who submits the form will be getting the FinCEN e-mail. It has held true in the couple of the initial filings we submitted when we first started discrete filing. Am I missing something?
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#1725117 - 07/31/12 12:10 PM Re: Discrete Filing - delays? Compli(cated)
Indy Banker Offline
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Joined: Aug 2010
Posts: 528
Yes, our experience has been that the user that filed the form gets the acknowledgement confirmation when sent, and then an e-mail confirmation as well. A supervisory user can go in and review all forms filed by the organization, but doesn't get acknowledgements for each user that submits.

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#1725144 - 07/31/12 01:14 PM Re: Discrete Filing - delays? Compli(cated)
Compli(cated) Offline
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Joined: Mar 2011
Posts: 185
Wisconsin
Well, that is the problem: Asst. BSA Officer is assuring me that all the filings were done; since I was not the one submitting the forms, I didn't receive any e-mails and I am only seeing a few filings as the supervisory user, far from all of them.

Before I started looking into the possibility that the filings were not actually submitted, I wanted to make sure that there are no delays on FinCEN's end.
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#1725319 - 07/31/12 03:39 PM Re: Discrete Filing - delays? Compli(cated)
banker1976 Offline
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Joined: Nov 2005
Posts: 346
Mid-Atlantic
I've not had problems either when viewing forms filed by other. Maybe you should have your Assistant BSA Officer sign into the BSA Efiling site with their username and then verify by looking at his/her track status and see if CTR's/SAR's have truly been filed.
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#1726427 - 08/02/12 02:43 PM Re: Discrete Filing - delays? Compli(cated)
Dani York, CRCM Offline
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Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
Not sure if this is related, but I just found out from the efiling help desk that the track status function is only showing 60 days worth of filings. They are aware of the issue and have escalated it to development to fix it so you can see up to 5 years of filings. So if the filings you are looking for are prior to 6/1, you won't be able to see them.
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#1727183 - 08/03/12 05:07 PM Re: Discrete Filing - delays? Compli(cated)
Compli(cated) Offline
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Joined: Mar 2011
Posts: 185
Wisconsin
Thanks banker. What you suggest is my last resort, but I didn't want to go there before I knew there was no other explanation for it.

Dani,we only went to discreet filing as of July 1, so all we have is one month of filings through FinCEN.
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