Since Christmas falls on a Tuesday next week, I will not be able to pull the FinCen report on schedule. Does it matter on what day we pull it? Does it have to be on Tuesday? Can I pull it on Thursday? Thanks in advance!

If you are referring to the 314A, you can pull it on Thursday.

Just sharing - Information from a vendor stated that due to the Christmas Holiday on Tuesday, December 25, FinCEN will be publishing their list for download on Friday, December 21.

Upon receiving an information request from FinCEN under this section, a financial institution shall expeditiously search its records...

You are not obligated to search until you receive the notice... Enjoy the holiday.

Thank you for all of the information!

I do have one more question that was just asked of me......when we get the notices to pull the reports, is there a time limit of days that we have to pull it by?

14 days

Oh, okay. Thanks so much!

There may be some ambiguity in asking when you have to "pull the reports." Note the language quoted above. You are to do the search "expeditiously," but it must be completed within 14 days. If you routinely wait until the 14th day to do the search you will be criticized.

I have never waited that long before, and do not plan to. I usually get it pulled the day of. I will be on maternity leave in a few months, and so I was asked about it from the person that is going to pull it for me while I am gone. Thank you for your help.

Generally it is 14 days -- the specific due date is listed along with the tracking # of each case. Periodically there are special instructions that require a shorter timeframe.

Just sharing - in the event of a natural disaster or something else beyond the bank's control - directly reach out to FinCEN as to why you might not be able to make the response date. During Hurricane Sandy here in NJ they were very understanding and only requested an e-mail be sent to the 314(a) fincen e-mail address providing the reasons why the bank might be late and what is the expected completion date. We added that process to our procedures.

Related to the December 25th submission, I know they published it early, but are we okay to complete our search today? I know I am probably overthinking this, but if we searched today and then sold an official check to one of the bad guys on Monday, wouldn't we need to report that since the list isn't technically dated until Tuesday?

Again, realize the chances are slim and I am probably putting too much thought in to this, but trying to follow the rules.

It's a one time search. Once you have searched you are instructed to never use the list again...

Right, I just wasn't sure if we could search before the actual date of the report even though they pushed it early.

Yes, you can run the search as soon as you get the list.