314(a) Distribution List

The folks at my bank are looking into having FinCEN send the biweekly notices to a e-mail address that will act as a distribution list. The idea is to make maintenance easier in that we don't have to file anything with the FDIC to change contact info, all we have to do is change the distribution list on our side.

From what I can tell, this is not what the feds have in mind for how this works, but I thought I'd come on here and see if anyone else out there has tried this approach.

Thanks!

I have done something similar before we switched to the Fincen database method. We used our "compliance@" email address so that we weren't faced with confusion if anyone left the bank. We kept access within compliance and provided the list to those who had any manual checking to do. I imagine if you keep access limited to those authorized to work on the 314a searches you would be okay.

I think you are running at risk if you do that, that was a discussion we had with our Regulators (OCC) and they did not like it at all

The e-mails are only notices that the list is available on the FinCEN web site, so I see no danger in a group e-mail address as described above. As long as the users who can then access the site and download the lists are limited, you should be OK.