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#2142097 - 08/15/17 05:02 PM
UPDATED CTR FORM
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Member
Joined: Jul 2008
Posts: 96
Central Missouri
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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
Carol Hopper
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Junior Member
Joined: Nov 2015
Posts: 43
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Correct, we are not seeing it as well.
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#2142104 - 08/15/17 05:29 PM
Re: UPDATED CTR FORM
Carol Hopper
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Member
Joined: Jul 2008
Posts: 96
Central Missouri
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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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If you aren't part of the solution - Then you are part of the problem.
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#2142123 - 08/15/17 06:11 PM
Re: UPDATED CTR FORM
Carol Hopper
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Member
Joined: Dec 2013
Posts: 82
221B Baker St.
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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
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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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
Carol Hopper
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Member
Joined: Jul 2008
Posts: 96
Central Missouri
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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
Carol Hopper
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New Poster
Joined: Sep 2013
Posts: 18
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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
Carol Hopper
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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Well, they are actually going to make their deadline?
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#2143785 - 08/28/17 01:42 PM
Re: UPDATED CTR FORM
Carol Hopper
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New Poster
Joined: Aug 2017
Posts: 2
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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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#2143835 - 08/28/17 05:37 PM
Re: UPDATED CTR FORM
Carol Hopper
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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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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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#2143836 - 08/28/17 05:38 PM
Re: UPDATED CTR FORM
Carol Hopper
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New Poster
Joined: Aug 2017
Posts: 2
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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
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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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
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Diamond Poster
Joined: Jul 2007
Posts: 1,022
Pac NW
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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. 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
Carol Hopper
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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Not a problem. It's helpful information for anyone who does have access.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
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#2143973 - 08/29/17 01:54 PM
Re: UPDATED CTR FORM
Carol Hopper
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Gold Star
Joined: Nov 2000
Posts: 489
KY
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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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Opinion expressed are my own and not necessarily those of my employer.
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#2144303 - 08/30/17 05:42 PM
Re: UPDATED CTR FORM
Carol Hopper
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Platinum Poster
Joined: Jul 2007
Posts: 501
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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
Carol Hopper
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Power Poster
Joined: Nov 2004
Posts: 6,842
Illinois
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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
Carol Hopper
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Platinum Poster
Joined: Jul 2007
Posts: 501
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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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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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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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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
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#2144365 - 08/30/17 08:43 PM
Re: UPDATED CTR FORM
Carol Hopper
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Platinum Poster
Joined: Jul 2007
Posts: 501
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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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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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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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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
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#2146222 - 09/15/17 01:32 PM
Re: UPDATED CTR FORM
Elwood P. Dowd
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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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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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
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#2146227 - 09/15/17 01:44 PM
Re: UPDATED CTR FORM
Carol Hopper
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Diamond Poster
Joined: Feb 2014
Posts: 1,030
Southern U.S.
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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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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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In candor, I cannot prove that either way. All of the relevant links on the E-filing system: 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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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
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