I have auditors on site that are requesting a Track Organization status report in excel format from the BSA e filing website. The user guide for the modernization upgrade that occurred in June of this year states that The BSA E-Filing System retains administrative data as follows: (1) Acknowledgment data are retained for 30 days after being opened or 60 days after being posted, whichever comes first; (2) Alert data are retained for 30 days after posting; and Track "Status" data (under the "Filing" section) are retained for 1825 days (i.e. 5 years) after achieving "Accepted" or "Rejected" status.
Since the website would not give me any data beyond 30 days for the Track Organization stat report - I sent an email to the help desk to inquire why the data for Track organization status would not go back to the 1825 days that the guide says it contains. They answered me with this: Please note that Messages/Acks remain in the view inbox for “60 days” and when opened, down to “30 days". If you provide a Tracking ID #/s, we can provide a copy of the ack/s for you We only provide copy of acknowledgments for Batch files, not Discrete files. This does not even address the question I was asking about. I find that this help desk is as useless as the HMDA help desk. Has anyone else run up against this issue since the website upgrade in June. I know this worked before, as I have an excel report that I pullled for the OCC last year. I can only show the OCC what the system will provide me and the copies of the emails I have sent to the helpless desk and their lame response. Looking to see if anyone else has had this issue. I appreciate any feedback

FinCEN's instructions have always been that a filing institution is responsible for retaining its own acknowledgements and that institutions are not to rely on FinCEN for retaining this information.

Those using automated monitoring systems to file FinCEN reports upload the acknowledgments into the system and the system retains the BSA IDs for filings. When I filed discretely, I kept .pdf copies of my acknowledgements.

If you have information in either of these formats, that should be adequate to satisfy auditors. For the consultants that work for my audit firm, I always caution them to never require information in a particular format because the retention requirements generally don't mandate what format information be retained in, only that it be retained. We may request information in a particular format because it's easier for us to review, but we should never be citing an institution if they have the information, but just in a different format.

Do you have your acknowledgments? If yes, then provide what you have to your auditors. If no, then it's time to start keeping them since FinCEN changed how much information is readily retrievable through the e-filing site.

Thanks Brian. We do use an automated monitoring system to file FinCen reports. We retrieve and import the acknowledgments into the system once we receive the email notification. I can produce a report from this system that shows all the CTRs filed and the confirmed acknowledgements. I was concerned that I could not provide the BSA Efiling system document requested by the OCC. I don't want to start a BSA Exam off on the wrong foot.

Shouldn't the OCC be able to pull documents from the e-filing system directly?

Another anon here: Coincidentally I was just pulling my institution's track org status CSV file today. Mine indeed goes back a long while - I didn't check if it was 5 years - but there were 12+ pages available for download. I make it a habit to download this every 3 to 4 months, and for one reason only: some examiner might demand (unreasonably) that I produce it.

If I have my FinCEN tracking number and related documentation, there's no reason I should ever have to produce anything from FinCEN's site, and in fact, no one has ever asked me for it.

Obvious tip here, but I'll mention it just in case: Go back to the website and be sure to change the drop-down menu from 30/60 days to "All." I'd be surprised if they really only had 30-60 days for you, and today they had at least 4 months worth (plus 10+ additional pages) for me.