Bank A merges with Bank B and the merger is closed on August 1, 2016 with Bank B being the surviving entity. Data conversion is not until October 1, 2016. Between August 1, 2016 and October 1, 2016, can Bank A still continue to file CTRs and SARs under its legal name, TIN and TCC ID or must all reportable CTRs and SARs after the merger date be filed under Bank B's legal name, TIN and TCC ID? Can someone provide me with a reference to IRS or FinCEN information to support your response?

In a bank not 100 miles from you, the regulator directed the bank to amend every CTR filed since the date of the merger to show the name and EIN of the surviving institution. I suggest you write to the Helpline, document their response, and follow their instructions.

I have submitted a question as suggested and will post the FinCEN response when receive for use by other BOL users.

We are going through a similar situation right now but also went through this about 5 years ago. All CTRs and SARs filed between merger and actual conversion had to be filed under the surviving bank's name/EIN. I'm curious to hear what FinCEN's response it. Thanks for keeping us posted!

Here is the response I received from FinCEN's Resource Center:

Regarding the CTRs, when A acquired B, the latter will fail to exist, so the customers of B bank become customers of A bank - the banks are one legal entity now. The CTRs should be filed under the legal name of the acquiring bank - A; additionally, all CTRs should contain the name Bank A as well as its EIN (do not use name/EIN of acquired bank). In other words, the CTRs should reflect the post-acquisition FI name and EIN.

For the SARs, the same reasoning applies. Bank A must file under their name and list all activity for both banks in the narrative section. Also include the date and other particulars relating to the acquisitions. Just because a bank was acquired would not relieve the surviving bank from filing.

Is the response received from FinCEN's Resource Center still accurate for today's mergers?
Thanks for any help.

I'm not sure why you would think it would be any different. I did note that the response from FinCEN had the bank's mixed up.

The conversion date is not relevant. Beginning on the date the deal closes all CTRs and SARs should be filed the name of the surviving institution. The bank that was acquired no longer exists.