In August 2017.


http://bsaefiling.fincen.treas.gov/docs/CTRXMLAnnouncement_May2017_Final.pdf

Informational webinar available from FinCEN on the morning of 06/21/17.

Concerning the changes on the new CTR, Part II-Amount and Type of Transaction(s). Check all boxes that apply, #24-adding an option "Shared Branching". Does anyone know exactly what that means? I want to think it means if you have multiple transactions on one customer that occurred at more than one branch on a single day over $10,000. Is that right? Appreciate the help!

I don't think that's right. I did a little research, and it looks like that's more geared towards credit unions that allow customers to use each other. I.e., I can use my local credit union who I am a member at as well as one a thousand miles away that I'm not a member at, but only have to have an account at my local one.

I believe MScarn is correct, this has to do with institutions that have agreements to process transactions for other institutions.

Thank you so much for the help. I'm glad I asked it about it. I've been looking for information on it, but couldn't find it. Thanks again!

I'm from a Credit Union, and Shared Branching is something that we pay to participate in. Our members can do transactions at other participating Shared Branching locations.

February, 2016 FinCEN Notice explaining the rationale behind the changes. Primary impact is on bank holding companies that file on behalf of member banks and credit unions using shared branches.

The batch changes to XML format will affect every bank that files batches. The new format will be "available" in August and most likely will be mandatory at some future unspecified date in May 2018.

I'm sure that the new CTR discrete filing format will become mandatory at some point in time as well. This will have an impact on banks that save "templates" for frequent filers. You will need to update your template eventually.

I wonder whether FinCEN will have both the current and the new discrete filing formats available for a while.

Another change is the new requirement that we list the transaction amount at each location. Unless our core provider (JHA) steps up to the plate (?) we'll be figuring this out manually. I had submitted a comment letter to the ABA on this; obviously it didn't do any good . . .

Bump

Free webinar on "technical" issues mentioned in document linked by OP.

You make a really good point. That will affect every bank with multiple offices, not just CU's with shared branches. I read nothing about such a change, but I simply can't counter your observation. The instructions don't offer a helpful interpretation because they have not been updated; Version 1.5 (March, 2015) is still up on the User Test System.

Slides from the webinar

The expected audience was application and software developers from batch filers.The webinar was not intended for discrete filers. The webinar was recorded and FinCEN expects to make it available on their web site. Discrete filers will find little of value after the first few minutes, but should note slide #2 from those linked above to see when the changes will take effect and the impact the changes will have on their templates.

Thanks, Ken. We were one of the registered attendees that couldn't get in. Much appreciated.

Has anyone found the webinar on the FinCEN web site? I intended to link it here...