Every time I call FinCEN Regulatory Helpline with a BSA question that I can't answer on my own, the answer I always get back is from someone who sounds like he/she is unsure about the regulations and says "Um... we can't tell you what to do so um... it is up to you to decide and just document your decision." I am just curious is FinCEN not supposed to tell us how it should be done? Am I the only one getting this kind of answer? Just wondering...

I email instead of call, (frc@fincen.gov). They generally are helpful, and that way you have the reply in writing in case an auditor/examiner questions the answer.

Thanks but I did email them but called me back saying that they cannot answer my question via email and must inform me by phone only... I don't get it. Oh well...

In my experience, it depends on the question being asked of them whether they will respond back to an e-mail or call you instead. And if they do respond via an e-mail. 9 out of 10 times it's just with a link to existing Fincen guidance without any real further direction to my issue/question.

Another anon here:

I have had several questions, including emailed ones, go unanswered.

When they do answer, 4 times out of 5 it has been, "Here's a copy of the reg and guidance which you cited/referenced in your question." In other words, they don't actually answer anything. The only reason I ask them is because the guidance is unclear or vague, and their answer is: "Read the guidance."

I am still waiting on an answer from a message I left two weeks ago. I saw on my phone where they called, but did not leave a message about what I asked. ugh!

1) They are not going to put anything in writing other than what has been officially issued and been vetted by FinCEN. They are not going to issue anything that could be interpreted as a written interpretation.

2) They are not going to leave a message in a recording on an answering machine for the same reason.

Just an observation, I have saved messages from FinCEN that they have left messages in the past answering questions, so maybe they changed their procedures.

I just now got a call back from them, but the name came up Anonymous, I almost did not answer the phone.

Also, at one time they were giving reference numbers, but she did not give me one today.