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#2142097 - 08/15/17 05:02 PM UPDATED CTR FORM
Gr8hopper Offline
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Is anyone else not seeing the new CTR form when logging into BSA e-file?
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#2142103 - 08/15/17 05:27 PM Re: UPDATED CTR FORM Gr8hopper
Goodland Offline
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Posts: 29
Correct, we are not seeing it as well.

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#2142104 - 08/15/17 05:29 PM Re: UPDATED CTR FORM Gr8hopper
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Does anyone know a specific date- or is there something I need to have IT looking at to utilize the new form?
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#2142123 - 08/15/17 06:11 PM Re: UPDATED CTR FORM Gr8hopper
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Aug 15 is only a target date.
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#2142187 - 08/15/17 10:41 PM Re: UPDATED CTR FORM Sherlocked
Elwood P. Dowd Offline
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Slides from the FinCEN webinar

Slide # 2 says "...the CTR will automatically be updated in August with the changes." August isn't over, but FinCEN isn't exactly a slave to its own deadlines anyway.

It will be updated when it's updated; i.e. whenever anyone logs onto the e-filing system and it's a different form (presumably 1.3) then it's been updated for everyone. If you check and it's not there, then: it's not there.
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#2142212 - 08/16/17 12:56 PM Re: UPDATED CTR FORM Gr8hopper
Gr8hopper Offline
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Thank you everyone. I thought something slipped under my radar. Glad to know we just wait.
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#2142505 - 08/17/17 09:09 PM Re: UPDATED CTR FORM Gr8hopper
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A notice on the e-filing system today said it would be available on August 28th.

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#2142512 - 08/17/17 09:29 PM Re: UPDATED CTR FORM Gr8hopper
John Burnett Offline
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Well, they are actually going to make their deadline?
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#2143785 - 08/28/17 01:42 PM Re: UPDATED CTR FORM Gr8hopper
MarleneW Offline
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Does anyone know the exact date version 1.3 must be implemented by for discrete filers? Thanks

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#2143811 - 08/28/17 03:19 PM Re: UPDATED CTR FORM Gr8hopper
fmissle Online
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https://bsaefiling1.fincen.treas.gov/new...dated%20CTR.pdf
Quote:
Discrete filers will be able to utilize the new online form with the new and updated fields immediately on August 28th. If you have templates or saved versions of the existing CTR report, we will continue to accept these versions until June 1st, 2018.

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#2143835 - 08/28/17 05:37 PM Re: UPDATED CTR FORM Gr8hopper
John Burnett Offline
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Access to the link above requires authorization to access the e-filing system, and the use of a user ID and password. So if you aren't already authorized to be accessing the e-filing site, don't bother trying the link.
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#2143836 - 08/28/17 05:38 PM Re: UPDATED CTR FORM Gr8hopper
MarleneW Offline
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Thank you fmissle. Couldn't find a date anywhere. Now I see "messages" on FinCEN page. Appreciate your response.

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#2143877 - 08/28/17 07:28 PM Re: UPDATED CTR FORM MarleneW
Elwood P. Dowd Offline
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The previous version, 1.2, is still on the User Test System.
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#2143894 - 08/28/17 08:03 PM Re: UPDATED CTR FORM John Burnett
fmissle Online
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Originally Posted By John Burnett
Access to the link above requires authorization to access the e-filing system, and the use of a user ID and password. So if you aren't already authorized to be accessing the e-filing site, don't bother trying the link.


Sorry about that, once I was in I didn't even think about it.

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#2143907 - 08/28/17 08:22 PM Re: UPDATED CTR FORM Gr8hopper
John Burnett Offline
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Not a problem. It's helpful information for anyone who does have access.
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#2143973 - 08/29/17 01:54 PM Re: UPDATED CTR FORM Gr8hopper
StevenD Offline
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The previous version, 1.2 is also still available on the live e-filing system. You can "open a new form" with either the BCTR or the new CTRX version.
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#2144303 - 08/30/17 05:42 PM Re: UPDATED CTR FORM Gr8hopper
ComplianceGurl, CRCM Offline
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I looked at the new CTR for discrete filing. Does anyone else find it odd that Step 1 is Part IV, Step 2 is Part III, Step 3 is Part 1, and Step 4 is Part II? I would like to start creating templates but I'm afraid they might change this form again. I love my job, I love my job, I love my job..

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#2144313 - 08/30/17 06:00 PM Re: UPDATED CTR FORM Gr8hopper
BrianC Offline
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FinCEN made the format of the CTR consistent with the financial institution information on the SAR which also begins with Part IV and III.
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#2144314 - 08/30/17 06:10 PM Re: UPDATED CTR FORM Gr8hopper
ComplianceGurl, CRCM Offline
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So I wonder why....oh..forget it. :-) Thanks for the feedback Brian!

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#2144361 - 08/30/17 08:33 PM Re: UPDATED CTR FORM ComplianceGurl, CRCM
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Quote:
So I wonder why


Only after they put the reports out for public comment did they decide it was important to identify the filing institution first. They could not change the numbering scheme for the text boxes without putting the reports out for public comment a second time. So, they stuck with the original numbers for the text boxes, but did not put text boxes in numeric order.

Thus, permanently confusing those who prepare them...
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#2144365 - 08/30/17 08:43 PM Re: UPDATED CTR FORM Gr8hopper
ComplianceGurl, CRCM Offline
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Ken-I'm laughing...literally out loud. Thanks for replying. :-)

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#2145777 - 09/13/17 12:46 PM Re: UPDATED CTR FORM ComplianceGurl, CRCM
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Version 1.3 of the CTR now appears on the FinCEN User Test System. However, the instructions (also housed there) have not yet been updated.
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#2146222 - 09/15/17 01:32 PM Re: UPDATED CTR FORM Elwood P. Dowd
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I've spoken with a couple of banks whose vendors have not yet updated their online version of the CTR. That would only be problematic in connection with the "new" items 41 & 42; i.e. if the CTR is reporting aggregated transactions the bank would be able to list the locations where the transaction took place, but not the amount of cash in or cash out at each location. One banker said their vendor would have the updated form by next month. One said their vendor had not given them a date.

Based on Question 2 of the FAQ's for both the FinCEN SAR and the CTR,

FinCEN expects financial institutions to have the capability to submit information for any of the data fields in the FinCEN CTR or SAR (or any other FinCEN report).

The implication is that on CTR's where multiple locations are being reported, a limitation in the filing software would not be an excuse; i.e. the bank would either 1) file those CTRs on a discrete basis directly through the e-filing system or 2) be forced to amend any CTRs filed without the cash breakdown by location at some future date.

If anyone is offered a contrary opinion by the Helpline, please let us know.
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#2146227 - 09/15/17 01:44 PM Re: UPDATED CTR FORM Gr8hopper
Daisy Doodle Offline
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We're still talking about discrete filers right? Batch filers are mandatory May 2018?

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#2146250 - 09/15/17 02:16 PM Re: UPDATED CTR FORM Daisy Doodle
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In candor, I cannot prove that either way. All of the relevant links on the E-filing system:

Quote:
Hot Topics
FinCEN CTR XML User Guide Update/Release of Updated CTR
CTR Technical Webinar Presentation
FinCEN Announces Update to the Currency Transaction Report (CTR)


as well as the link to the slides from the webinar in an earlier post above, yield a "404" response; i.e. they are inoperative.
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