Just wanted to know if anyone else has received an e-mail from:

James F. Sloan, Director
Financial Crimes Enforcement Network
Date: August 23, 2002
Re: Survey on Costs of Filing Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs) and Measures to Reduce Recurring CTR Filings

Just wanted to get some feedback before I completed this survey...I thought it was a little unusual.

Thanks

I received the same e-mail and wondered about it myself. Are you going to participate?

We just received the fax and plan to review the questions today.

We received the email yesterday. We are reviewing it as we speak.

Sent it in yesterday. You will need to know how many customers you have and how many employees you have dedicated to BSA compliance (from branch staff to compliance)in order to complete the survey. I just made a best effort guestimate.

They are also seeking guidance on our thoughts on where we would see the greatest reduction in BSA processing time. I think it would be to remove 50% rule on eligible non-listed businesses. It take tremendous time to try to determine gross revenues for Phase II exemptible customers.

We received it too, with the full name (rarely used) of our BSA officer (thankfully not me). My first thought was to question its source, but I forwarded it on. Can anyone speak to its validity?

I received it today....at my email address, however, to the attention of the former compliance officer of 2 years ago! Hey, maybe I need to return it

Have not looked at it, there are other items that take priority.

Thanks everybody for all the good info...I'll try to go over it this week...I also e-mailed FinCEN to check for validity. I will let you'all know what I receive.

We received this as well. A key person needed to review it is on vacation this week, so we will go over it next week.

I'm sure many would appreciate any other information on what the survey is asking. I didn't want to log into the survey prematurely!

Are they ready for this suggestion on CTR's?

DO AWAY WITH CTR FILING COMPLETELY!
CTR's serve almost no practical purpose any more. Any and all information that FinCEN needs can be obtained from the SAR. Period!

And think about it - the majority of SAR's are for "Structuring." How many "structured" transactions are really money laundering vs. how many "structures" are people thinking that the IRS doesn't need to know how much cash they have. Any unusual cash transactions would be reported on an SAR anyways!

How about another suggestion ......
Increase the reporting amount. $10,000 just isn't what it used to be.

Thanx for reminding me! I forgot all about it! (I'd better get hopping!)

I agree - raise the reporting amount! 90% of our CTRs are triggered by the customer "structuring". Very few people who "structure" are of the suspicuous nature!

Just did the survey. I don't know what value it will be, the questions wanted estimates of time and costs involved in the CTR function. I don't know how accurate it can be. Hard to guestimate, when the BSA person is also the vault person, safe deposit account person, etc., and her backup is the human resources, teller supervisor, and gardener. Hey, we're a small bank! Everyone pitches in. I get to do compliance AND the lunch room dishes!

Wow - I thought I was the only one who drew periodic KP... Misery loves company, I guess.

I'm another CO with KP duties, BUT I get to change the burned-out light bulbs over the drive-through lanes!

Yes, we also received the survey. I thought the same thing. And the questions are not easy to answer either.

FYI...I got a call today from FinCEN and they acknowledged that e-mail was sent by their office and they will use survey in response to the USA Patriot Act.