Would someone be kind enough to give me some very entry level info on 314(b).?? how is the information request received? does a 314(b) request for info come from FinCEN?
JacF
Power Poster
Joined: Nov 2001
Posts: 6,719
PA
314(b) sharing is done bank-to-bank. While participants have to register with FinCEN, the shared information does not actually pass through FinCEN's hands.
I have seen 2 separate "Notice for Purposes of Subsection 314(b) of the USA Patriot Act and 31 cfr 103.110", both forms ask for the same info but look very different. It appears that one (Appendix A to subpart H)is an earlier edition of the form I completed- I completed the January 2006 Department of Treasury form. The form was mailed and I have received acknowledgement from treasury. Is my registration complete or is there something else that I need to do? of course i am still working on policy/procedures! your response will be greatly appreciated.
The 314b has to be refiled annually, so if you did it in 1/06, it is time to refile. You can use the FinCEN site to register and they will provide an e-mail verification that you filed.