Our Bank has a few MSB customers that were registered in 2006. The registration calculator on MSB.gov shows that the customers needed to renew their registration by December 31, 2007. We've already sent out letters to the customers requesting updated registration. My question is, since some of the customers are within two calendar years of their registration date, have they technically lapsed? If we receive their new registration by two calendar years from their 2006 registration can we avoid a SAR filing?

Additionally, how is the MSB registration schedule affected when a customer's registration lapses? I know the registration schedule is determined by the MSB's originial date of registration, I just don't know how an expired registration affects that schedule.