Would like to know if anyone is using the BSA Direct E-filing system with Fincen. How is it working? Is their a cost associated with filing? What internal procedures would you set up for getting the information from, say Teller to the BSA officer for input?

We started using it the first part of the year. It is easy to use, efficient and you get a reply confirming that it was sent.

It took a few days to get set up because of the digital certificate required. Be patient and know it takes a few days to a week to get it all set up.

Our process is similar to before. Person doing the transaction completes the CTR and passes it on to the BSA Officer or BSA Assistant to be sent through the e-filing system. The CTR is printed out and reviewed prior to sending.

I recommend using it. No cost for you to use and it works great.

How do you review the CTR from the offices before putting them online? We want to eventually go to E-Filing but aren't sure how to set up reviewing the CTR the teller's complete before sending it to the IRS. Right now we do it with paper which is slower.

They fax us all the information and send the original with the courier.

We use the CTR batch file option. We use an online teller system and control the printing of CTRs in a central location. The CTR automatically appears in the path of the teller when a reportable transaction is conducted (and when a subsequent transaction occurs that requires a CTR to be updated with transactor information). Since no automated system can identify every reportable transaction, each teller also has the ability to create a CTR if needed.

Prior to having this system, all CTRs were prepared by the teller and routed to the BSA Department for review and filing. Reportable transactions that were not identified on a branch level (such as a CTR for multiple smaller deposits aggregating over $10,000) were completed by the BSA Department staff. The review process included comparison to various internal reports each day to insure that all reportable transactions were identified and that CTRs were properly completed.

So you review the CTRs from the tellers they complete on the teller system when they print out in the central location? Then you reinput them on the E-File system?

We have been using it since the first of the year. We put the Pure Edge Viewer on each teller and manager machine in each branch (11 of them). The head teller is responsible for completing the form which is saved and e-mailed to their manager for review. The manager makes changes (or not), saves and forwards to BSA area for review and digital signature. BSA clerk reviews digitally signs, saves and sends. CTR copies and acknowledgements are burned onto CDs. We pull and burn our digital records of checks, deposits, etc. the majority of the time. There is almost no paper and we can pull additional records if needed.

We tried not having the manager review but FDIC thought it wiser to have one more review. We had 14 errors (8 insignificant) in about 425 CTRs and FDIC seemed to think that was high.

Treasury now has us doing the FinCEN input so zero errors is a target. That is always my target when I have someone else doing the input also. Somehow I don't think FinCEN's input was much better when they re-typed everything. Their people are now free to "do more analysis and be proactive" in their anti-money laundering effort.

Thanks Greg! I was wondering how you could review CTR electronically - using paper is too clunky. We have to have a supervisor and a compliance specialist review the CTR before we send it on too otherwise the errors are too high. It takes a few set of eyes to catch all the errors.