FinCEN postpones mandatory use of new formats

Posted By: John Burnett

FinCEN postpones mandatory use of new formats - 12/20/11 06:55 PM

FinCEN announced that the deadline for financial institutions to utilize FinCEN's new Currency Transaction Report (CTR) and Suspicious Activity Report (SAR) for reporting purposes will be extended to March 31, 2013.


FinCEN still thinks it has a valid case for mandating e-filing by June 30, 2012, but it extended the date for use of the new, expanded, file formats for CTRs and SARs in response to industry complaints that the original 6/30/12 date would not provide enough time for implementation and testing.
Posted By: Elwood P. Dowd

Re: FinCEN postpones mandatory use of new formats - 12/21/11 12:01 PM

As the forms are not available and the industry hasn't even seen prototypes, it seems appropriate that their required use would be delayed... wink
Posted By: AuditorK

Re: FinCEN postpones mandatory use of new formats - 12/21/11 01:37 PM

Originally Posted By: Ken_Pegasus
As the forms are not available and the industry hasn't even seen prototypes, it seems appropriate that their required use would be delayed... wink



I was thinking the same thing...what do the new forms even look like?!!?
Posted By: rlcarey

Re: FinCEN postpones mandatory use of new formats - 12/21/11 02:09 PM

Well, IMHO since mandatory e-filing will be required, there will probably not be any forms. You would have to refer to the new proposed e-filing specification guidelines.
Posted By: Kathleen O. Blanchard

Re: FinCEN postpones mandatory use of new formats - 12/21/11 01:58 PM

I agree. No "form" in the traditional sense. But oh the content!
Posted By: Kathleen O. Blanchard

Re: FinCEN postpones mandatory use of new formats - 12/21/11 02:00 PM

Specs for the electronic "form":

http://www.fincen.gov/news_room/nr/html/20110902.html
Posted By: Doug Hendrickson

Re: FinCEN postpones mandatory use of new formats - 12/21/11 09:04 PM

I love how the changed the web-site already and have all the current forms under "Legacy Forms".
Posted By: Elwood P. Dowd

Re: FinCEN postpones mandatory use of new formats - 12/22/11 03:00 PM

There will a "form" to the extent e-filers currently have to fill out a form, albeit electronic; I did not suggest they would be available on paper. Although the original requests for comment made it clear that paper filing would still be possible with the revised CTR, SAR, and DOEP, subsequent decisions appear to make that unlikely.

If everyone wants to call them "dynamic information collection devices," as some of the folks I've talked to at FinCEN do, knock yourself out. I'm still going to call them "forms." wink
Posted By: rlcarey

Re: FinCEN postpones mandatory use of new formats - 12/22/11 03:41 PM

Well, the virtual form is already published. Each required data field is described in these documents for both the new CTR and SAR:

http://bsaefiling.fincen.treas.gov/news/FinCENCTRElectronicFilingRequirements.pdf

http://bsaefiling.fincen.treas.gov/news/FinCENSARElectronicFilingRequirements.pdf
Posted By: Elwood P. Dowd

Re: FinCEN postpones mandatory use of new formats - 12/22/11 06:47 PM

Thanks!
Posted By: AnnRoy

Re: FinCEN postpones mandatory use of new formats - 01/25/12 04:57 PM

The proposal also mentions reducing the e-filing deadline from 25 days to 15 days. Is this effective in March 2013 or June 2012?
Posted By: rlcarey

Re: FinCEN postpones mandatory use of new formats - 01/25/12 05:46 PM

The new filing deadline goes with the new form, so when you start using the new form, you will have the new deadline.
Posted By: dottiec

Re: FinCEN postpones mandatory use of new formats - 01/26/12 04:13 PM

Everything seems to discuss batch filing standards. If we will be e-filing discrete forms, where do we find information on when the new format will be required?
Posted By: Elwood P. Dowd

Re: FinCEN postpones mandatory use of new formats - 01/26/12 05:12 PM

FinCEN announcement. In terms of when use of the form is required, they make no distinction between batch and discrete filing.