By now, all of you should have experience working with the new CTR e-Filing format. Last week there was some buzz about problems using the e-File system at FinCEN. How are things going now? Is the system responsive and allowing you to complete your filings without significant hassles? If you just finished your changeover from e-Filing the legacy format CTRs, have you sorted out the new fields and instructions on the FinCEN CTR data filing format? We know that FinCEN checks out our discussions in this forum (and we welcome that!), so are there still questions you want to see addressed?

Our folks love it. We have been using it almost since the release so that we could work the kinks out and maybe have better access to the hotline if there were questions (before there were a million people calling at the last hour). We have a lot of commercial customers who bring in multiple deposits at one time for their other commercial accounts as well as their personal accounts. Although the old "form" allowed for this, this format seems much more user friendly. I think we would give it a thumbs up!

We have been using it for a couple of months now with no issues. We also switched AML vendors to Verafin which populates the CTR and SAR form for us. Between the two changes we are loving it. Efficiencies have greatly improved and we were able to move the CTR process to a back office function!

I did notice the forms on the site are now version 1.2, so I had to update my saved forms that I use. It appears that the slow upload/timing out issues are all resolved, so that's nice!

I've got some issues with the new Adobe version and opening things in Firefox, but I can still get it all done in IE at least.

Now if only my core processor would get things up to speed and get the new form loaded or find another solution, that'd be great. But, I've been converting the old form to the new form for the last six months, so it's no different now.

The e-filing Web site is still slow at times but we are able to sign-in and file batches without problem. Insofar as the new forms, I like the CTR form and find it more logical than the legacy form. I wish I could say the same nice things about the new SAR form. I find it difficult and complicated with very unclear instructions (see paying or selling location). Our vendor (BAM) does not populate many of the "non-critical" fields on both the CTR and SAR forms which requires alot of manual additions since we want to file them with information that is available on our core system. They also did not upgrade the front-end system for CTRs so the backoffice has to do alot of revisions before they can be filed.

We began E-filing in March and have been trying to adapt our systems to the new CTR 112 Form. Our biggest hurdle at this hour is with the NAICS code. We have been assigning a six-digit NAICS code to our business customers for several years. The list of acceptable "drop down" NAICS codes from the FinCEN website are either three or four-digit codes. As a Jack Henry Bank, we are told this is the data that can be imported into the new form. We do not feel that we should have to go back and "redefine" our codes to match the 2007 data currently being used by FinCEN in order to have this information populated into the CTR field. We have also been told by our regulators, that while the NAICS field is not a required ("*") field, if we have it we are to provide it. What's the answer?

Lisa

We've also been using it for a few months now and have not really had any problems with the form or the E-filing system. The system does have some slow times but I noticed it was during peak times in the work day so have just been filing either early morning or late afternoons without a hitch. I did notice yesterday and today was really fast, so maybe they fixed something on their end as well in anticipation of the mass filings headed their way LOL

Other than the enhanced monitoring, NAICS is the biggest hassle. We dont have software to worry about but having never dealt with these codes before it is a bit of a learning experience. Not sure how much we are supposed to make the occupation fit the field or the fields fit the occupation. It would be a lot easier if they used the full list. How can their not be a government worker code? Maybe fincen is not worried about ctrs on government employees...


edit: I do know of the 92(_) series. They are just very broad an other options appear to fit better).

At the Top Gun conference, Ken Goliher made it quite plain that you can go with an either/or on the form. If you know the NAICS code and are using the 2007 3-4 digits codes, then go ahead and populate that field. If not, continue to list the occupation as you have done in the past. There is no requirement to enter date in both 9 & 9a.

Matt, is the SAR also updated to version 1.2? If so, can you email one to me as an attachment? jburnett@bankersonline.com

I only noticed it on the CTR actually, I should have specified. I did just check though, and no, the SAR is still 1.1.

Sorry for any confusion!

Is there any update as to what changed from CTR v 1.1 to 1.2. I can't find anything thus far. Will Fincen still accept 1.1 forms?

Will Fincen still accept 1.1 forms?

There are no "forms"

.. Yes there are. We file each CTR individually via the e-filing system.

The only changes I saw were some updated "hover" instructions.

Thanks John!!

But what you are actually sending them isn't the form; it's the data collected using the virtual form.

If you are doing it through FinCEN's discrete filing system, then whatever pops up is the current template. You might think it looks like a form, but all you are doing is providing them the bytes. There are no more forms.

I'd like to know as well if v1.2 is much different than v1.1.

Can we still submit v1.1 of the report?

Can we still submit v1.1 of the report?

Let's try again. there is no report to submit. If you are discrete filing, whatever appears on the FinCEN website is the current format. The report/form is not submitted, it is just the data you enter into the specific fields. If you are batch filing, it is nothing but a file of bytes.

Was any official notice sent out regarding the updated formats for the CTR? The only way I knew about the change from 1.1 to 1.2 was reading this thread...how do they expect us to keep up with the changes?

Ok. When we discrete file FinCEN asks us to upload or create a new form. So I apologize for calling it that. We opt to upload a saved "form" that we have reviewed to submit.

I understand the form itself doesn't get submitted, I think you are focusing on the wrong part of this question. Some of us have templates and want to make sure that the "file of data bytes" will be accepted if the data is entered via 1.1 and not 1.2, or if all we have completed but not filed need to be updated with 1.2.

The only reason this was brought up in the first place is that most of us that don't work for a bank (like John) do not have access to the actual FinCEN filing website. The only thing that we get to see is when they change it so that we can access it through other means. If they change a drop down or two - you will immediately see it when you are doing the actual filing. There have been no changes to fields or field formats unless it has been issued in the official electronic filing guideline documents.

Not to mention examiners/auditors who are more than quick to point out that on 4/3/13, your bank used version 1.1 when it should have been using version 1.2 blah blah blah

If you have downloaded a CTR to create a template, the template won't update itself, of course. I don't know whether FinCEN posts any alerts to say that a new version of the CTR is in use, since I cannot get inside the live submission site.

As I said earlier, the only thing that has changed (so far) is the wording in some of the hover pop-up instructions. One item that I know has updated instructions in version 1.2 is item 2.

So whether you submit information using CTR data collection format 1.1 or 1.2 won't matter -- the file will be identical.