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#1965421 - 09/29/14 05:48 PM Change to Report Names in BSA Efiling?
Dani York, CRCM Offline
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Dani York, CRCM
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TN
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
TXBSA Offline
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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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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
John Burnett Offline
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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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#1965497 - 09/29/14 07:54 PM Re: Change to Report Names in BSA Efiling? Dani York, CRCM
Beachbum, CRCM Offline
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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
bankerdiva2 Offline
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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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Noticed today that the Batch file name for CTRs is included on the acknowledgement too.

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#1965944 - 10/01/14 01:08 PM Re: Change to Report Names in BSA Efiling? bankerdiva2
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Originally Posted By: bankerdiva2
I know on SARs we aren't supposed to use the subject name in the file name.
When did I miss this?

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#1965949 - 10/01/14 01:11 PM Re: Change to Report Names in BSA Efiling? Dani York, CRCM
BrianC Online
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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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#1965951 - 10/01/14 01:15 PM Re: Change to Report Names in BSA Efiling? Dani York, CRCM
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So it's about risk management then. No one including federal and state examiners have had issue with our naming convention but it's only "strongly suggested" by FinCen. Thanks Brian!

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#1965980 - 10/01/14 01:44 PM Re: Change to Report Names in BSA Efiling? Dani York, CRCM
rlcarey Offline
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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
John Burnett Offline
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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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#1966052 - 10/01/14 03:20 PM Re: Change to Report Names in BSA Efiling? Dani York, CRCM
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My bad, I misspoke, I was referring to line item #91 on 2nd page, Internal control/file number. The actual "filing name" is assigned by our AML software provider as they batch file for us and the customer name is not included.

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#1966226 - 10/01/14 07:02 PM Re: Change to Report Names in BSA Efiling? Dani York, CRCM
bankerdiva2 Offline
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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
Elwood P. Dowd Offline
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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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