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#1965421 - 09/29/14 05:48 PM
Change to Report Names in BSA Efiling?
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Power Poster
Joined: Apr 2005
Posts: 3,663
TN
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I filed a CTR on the 25th and as far as I can remember, the report names were still FInCEN CTR, FinCEN SAR, etc. Today when I logged into BSA Efiling, the report names have changed to Report 112-CTRBatch, Report 112-CTR, etc. Did FinCEN send anything out about this change? Mostly I just want to make sure I'm on the legit site and haven't accessed a spoofed site.
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#1965431 - 09/29/14 06:03 PM
Re: Change to Report Names in BSA Efiling?
Dani York, CRCM
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100 Club
Joined: May 2006
Posts: 170
TX
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I noticed the same thing when I accessed the site this morning as well. The menu options have also changed order.
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#1965432 - 09/29/14 06:04 PM
Re: Change to Report Names in BSA Efiling?
Dani York, CRCM
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Member
Joined: Sep 2014
Posts: 57
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I saw that too! The report version looks to be the same though, so I don't think that they changed anything on the reports.
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#1965489 - 09/29/14 07:48 PM
Re: Change to Report Names in BSA Efiling?
Dani York, CRCM
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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That FinCEN would change ANYTHING related to e-filing without notice (at least a notice on the e-filing login page) is not unexpected, given some of its other examples of disregard for reasonable communication, but it is just plain short-sighted. I can only wonder at the number of [curious/panicked] (select one) phone calls the FinCEN help lines gets as a result.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1965497 - 09/29/14 07:54 PM
Re: Change to Report Names in BSA Efiling?
Dani York, CRCM
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Gold Star
Joined: Dec 2006
Posts: 499
Knee Deep in Regs
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I wonder if the disregard for reasonable communication extended to the Helpdesk as well? It wouldn't surprise me if they were just as unaware as we were.
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#1965732 - 09/30/14 05:08 PM
Re: Change to Report Names in BSA Efiling?
Dani York, CRCM
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100 Club
Joined: May 2011
Posts: 110
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For CTR discrete filers (unsure of effect on Batch filers), there is also a filing name associated with the acknowledgement now. I personally use the person who I am filing the CTR on as part of my naming convention and am hoping there won't be pushback from regulators or auditors because of it. I know on SARs we aren't supposed to use the subject name in the file name.
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#1965763 - 09/30/14 06:32 PM
Re: Change to Report Names in BSA Efiling?
Dani York, CRCM
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100 Club
Joined: May 2006
Posts: 170
TX
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Noticed today that the Batch file name for CTRs is included on the acknowledgement too.
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#1965949 - 10/01/14 01:11 PM
Re: Change to Report Names in BSA Efiling?
Dani York, CRCM
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Power Poster
Joined: Nov 2004
Posts: 6,716
Illinois
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FinCEN SAR FAQ #5 5. What do I enter for “Filing Name”? The filing name can be any name the financial institution chooses to use to identify the specific filing (e.g., Bank SAR 4-4-2013). The process for assigning filing names is for the financial institution to decide, and can assist the financial institution in tracking its BSA filings. We recommend using a naming convention that will be easy to understand and track for recordkeeping and audit/examination purposes. FinCEN strongly recommends, however, that FinCEN SAR file names not include the names of subjects as this may lead to the inappropriate disclosure of the SAR, which is prohibited by law and regulation. SAR FAQ's
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#1965980 - 10/01/14 01:44 PM
Re: Change to Report Names in BSA Efiling?
Dani York, CRCM
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10K Club
Joined: Jul 2001
Posts: 83,363
Galveston, TX
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No one including federal and state examiners have had issue with our naming convention
Here, let me correct this for you:
No one including federal and state examiners have had issue with our naming convention yet.
Mainly probably because none of your examiners have bothered to read the FAQs.
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#1966037 - 10/01/14 02:52 PM
Re: Change to Report Names in BSA Efiling?
Dani York, CRCM
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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Consider that, if you retain each SAR filed in a file on your institution's computer or server, even if it's in encrypted form or password protected, it will probably show up in a file list for the folder in which it's maintained. If the customer name is part of the file name, it could be seen by individuals with no need or reason to be aware of SAR filings (let's use your IT staff, for example). That's sufficient reason, I think, not to incorporate customer names in your SAR file naming convention.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#1966226 - 10/01/14 07:02 PM
Re: Change to Report Names in BSA Efiling?
Dani York, CRCM
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100 Club
Joined: May 2011
Posts: 110
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Does anyone see that there may similar "strong suggestions" for CTR filing names not displaying?
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#1966229 - 10/01/14 07:05 PM
Re: Change to Report Names in BSA Efiling?
bankerdiva2
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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No. CTR's are not "confidential."
John's made the best case I've heard for not using the name of the subject in the name of the SAR, but I still think the prohibition rises to the level of paranoia. In most contexts, if I'm looking at the file name I'm a bank employee and I'm one click away from actually opening the file and reading it, not just knowing that a SAR was filed.
If I'm not clear about this: I'm not making a case for ignoring the direction. That would be ridiculous. I'm just saying it's dumb.
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