Skip to content
BOL Conferences
Thread Options
#680884 - 02/06/07 06:02 PM 314(b)
nemsi Offline
Gold Star
Joined: Nov 2005
Posts: 383
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?

Return to Top
BSA/AML/CIP/OFAC Forum
#680961 - 02/06/07 06:51 PM Re: 314(b) nemsi
JacF Offline

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.

Return to Top
#681157 - 02/06/07 08:17 PM Re: 314(b) JacF
Big Dog Offline
Power Poster
Big Dog
Joined: Mar 2005
Posts: 2,659
Kennel
You can get additional information and sign up your institution by going to FinCEN
_________________________
CAMS, AMLP, AKC, K-9






Return to Top
#687035 - 02/14/07 07:59 PM Re: 314(b) Big Dog
nemsi Offline
Gold Star
Joined: Nov 2005
Posts: 383
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.

Return to Top
#687047 - 02/14/07 08:10 PM Re: 314(b) nemsi
Big Dog Offline
Power Poster
Big Dog
Joined: Mar 2005
Posts: 2,659
Kennel
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.
_________________________
CAMS, AMLP, AKC, K-9






Return to Top
#687052 - 02/14/07 08:14 PM Re: 314(b) Big Dog
nemsi Offline
Gold Star
Joined: Nov 2005
Posts: 383
Thanks Big-Dog.
This was my initial filing, effective Jan 07. based on what i read i am ok until Jan 08- is this a correct statement?

Return to Top
#687056 - 02/14/07 08:17 PM Re: 314(b) nemsi
Big Dog Offline
Power Poster
Big Dog
Joined: Mar 2005
Posts: 2,659
Kennel
Yes, just make sure that you write some procedures in the event you get a request.
_________________________
CAMS, AMLP, AKC, K-9






Return to Top
#688403 - 02/16/07 03:45 PM Re: 314(b) Big Dog
cbinder63 Offline

Platinum Poster
cbinder63
Joined: Dec 2001
Posts: 674
Colorado
Reference the 314(b) program in your BSA policy as well.
_________________________
Opinions expressed are my own.

Return to Top

Moderator:  Andy_Z