Good Morning,

I am looking up my MSB customers on the FinCEN website to make sure they are currently registered. When pulling up their registration form on the FinCEN website, if the date at the bottom of the form is older than 2 years are they not registered with FinCEN? If so would that require a SAR for being an unregistered MSB?

Thank you,

Depends - initial registration or renewal? When was it filed - in December for renewal by Jan 1st? Lots of different scenarios.

We have had issues with examiners saying we have not obtained current renewals for MSBs. The customer may have renewed their registration the first quarter of the year which should have been filed by December 31st of the previous year (based on initial registration). We are basing our information off the renewal date on the registration form and website which throws off the date cycle. That said, the customer shows as being currently registered. How are we to know when the customer filed their initial designation? The website states that renewals may be made throughout the year but by year end every two years. We appreciate any guidance you can provide. We are also reaching out to FinCEN for clarification.

The MSB website search annually drops MSBs that are not registered due to non-timely renewal, usually in April. I am not sure what your examiners are expecting. They are either registered or they are not. With the limited information available and if they are listed, I would be asking them specifically what would they expect you do.

Sorry for the delay in responding but I have been out of the office but thanks for the response. We are going to follow up with FInCEN as well to obtain clarification on the renewal timeline. This is the first time this has ever come up in all my many years in BSA and was FDIC.

Thanks again!