UPDATED CTR FORM

Is anyone else not seeing the new CTR form when logging into BSA e-file?

Correct, we are not seeing it as well.

Does anyone know a specific date- or is there something I need to have IT looking at to utilize the new form?

Aug 15 is only a target date.

Slides from the FinCEN webinar

Slide # 2 says "...the CTR will automatically be updated in August with the changes." August isn't over, but FinCEN isn't exactly a slave to its own deadlines anyway.

It will be updated when it's updated; i.e. whenever anyone logs onto the e-filing system and it's a different form (presumably 1.3) then it's been updated for everyone. If you check and it's not there, then: it's not there.

Thank you everyone. I thought something slipped under my radar. Glad to know we just wait.

A notice on the e-filing system today said it would be available on August 28th.

Well, they are actually going to make their deadline?

Does anyone know the exact date version 1.3 must be implemented by for discrete filers? Thanks

https://bsaefiling1.fincen.treas.gov/new...dated%20CTR.pdf

Access to the link above requires authorization to access the e-filing system, and the use of a user ID and password. So if you aren't already authorized to be accessing the e-filing site, don't bother trying the link.

Thank you fmissle. Couldn't find a date anywhere. Now I see "messages" on FinCEN page. Appreciate your response.

The previous version, 1.2, is still on the User Test System.

Sorry about that, once I was in I didn't even think about it.

Not a problem. It's helpful information for anyone who does have access.

The previous version, 1.2 is also still available on the live e-filing system. You can "open a new form" with either the BCTR or the new CTRX version.

I looked at the new CTR for discrete filing. Does anyone else find it odd that Step 1 is Part IV, Step 2 is Part III, Step 3 is Part 1, and Step 4 is Part II? I would like to start creating templates but I'm afraid they might change this form again. I love my job, I love my job, I love my job..

FinCEN made the format of the CTR consistent with the financial institution information on the SAR which also begins with Part IV and III.

So I wonder why....oh..forget it. :-) Thanks for the feedback Brian!

Only after they put the reports out for public comment did they decide it was important to identify the filing institution first. They could not change the numbering scheme for the text boxes without putting the reports out for public comment a second time. So, they stuck with the original numbers for the text boxes, but did not put text boxes in numeric order.

Thus, permanently confusing those who prepare them...

Ken-I'm laughing...literally out loud. Thanks for replying. :-)

Version 1.3 of the CTR now appears on the FinCEN User Test System. However, the instructions (also housed there) have not yet been updated.

I've spoken with a couple of banks whose vendors have not yet updated their online version of the CTR. That would only be problematic in connection with the "new" items 41 & 42; i.e. if the CTR is reporting aggregated transactions the bank would be able to list the locations where the transaction took place, but not the amount of cash in or cash out at each location. One banker said their vendor would have the updated form by next month. One said their vendor had not given them a date.

Based on Question 2 of the FAQ's for both the FinCEN SAR and the CTR,

FinCEN expects financial institutions to have the capability to submit information for any of the data fields in the FinCEN CTR or SAR (or any other FinCEN report).

The implication is that on CTR's where multiple locations are being reported, a limitation in the filing software would not be an excuse; i.e. the bank would either 1) file those CTRs on a discrete basis directly through the e-filing system or 2) be forced to amend any CTRs filed without the cash breakdown by location at some future date.

If anyone is offered a contrary opinion by the Helpline, please let us know.

We're still talking about discrete filers right? Batch filers are mandatory May 2018?

In candor, I cannot prove that either way. All of the relevant links on the E-filing system:



as well as the link to the slides from the webinar in an earlier post above, yield a "404" response; i.e. they are inoperative.

I saw that. I checked there first. Yikes.

I reviewed the slides and am now wishing I had downloaded them. However, I do recall that FinCEN stated that vendors had until May 2018 and that they would also accept Version 1.2 from discrete filers that have templates until May 2018 to give them time to create new templates.