I have possibly a stupid question. We are NOT a state chartered bank. We are an OCC regulated bank based in New York State. Do we fall under the requirement to file the BSA Compliance report?

Here is the definition given for Regulated Bank: “Bank Regulated Institutions” means all banks, trust companies, private bankers, savings banks, and savings and loan associations chartered pursuant to the New York Banking Law (the “Banking Law”) and all branches and agencies of foreign banking corporations licensed pursuant to the Banking Law to conduct banking operations in New York.

I don't believe National Banks are regulated by state regulators. Have you ever had a regulatory exam with the NY DFS?

Is this part of NYS DFS 504 that you are referring to?

If you do mortgages in the state than you may be subject to it at least on the mortgage side.