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Washington
BSA e-filing deadline is July 1
WASHINGTON (6/26/12)--Electronic filing of all Bank Secrecy Act (BSA) reports will become mandatory on July 1, Credit Union National Association (CUNA) reminds credit unions. The Financial Crimes Enforcement Network (FinCEN), however, has been encouraging financial institutions for weeks to begin using its BSA e-filing system "as soon as possible."

Currency Transaction Reports, Designations of Exempt Persons, and Suspicious Activity Reports are among the reports that can be e-filed. Almost all BSA reports will need to be e-filed as of July 1, FinCEN said, but Currency and Monetary Instrument Reports are not covered under the e-filing requirement.

FinCEN has said the switch to all-electronic BSA filing would improve efficiency, reduce costs for the financial industry, and enhance the ability of investigators, analysts, and examiners to gain better and more timely access to important financial information. Increased BSA E-Filing would also help speed up financial crime investigations, the agency added.

Financial penalties may be imposed on institutions that file non-electronic reports after the deadline, FinCEN said.

Small credit unions and other institutions that do not have internet connectivity, and file few BSA reports, were permitted to file hardship exemption requests ahead of the deadline. However, FinCEN noted, these exemption requests would only shelter those institutions from the e-filing requirements until March 31, 2013.

Some credit unions and other financial institutions that have the technical ability to e-file BSA Currency Transaction Reports (CTR) but are using aggregation systems that are currently incompatible with the BSA E-Filing System's batch and computer-to-computer reporting capabilities were also granted temporary exemptions. Those exemptions would expire on December 31, FinCEN said.

FinCEN has not published a list of organizations that were granted e-filing exemptions. However, the agency has released guidance, an archived webinar, and a list of frequently asked questions to help credit unions and other institutions manage the shift to an e-filing only BSA reporting system.

For these FinCEN resources, click the link.

CUNA has encouraged FinCEN to work with the National Credit Union Administration, state regulators, and third-party vendors to minimize compliance costs related to the e-filing switch. CUNA also suggested FinCEN exempt credit unions with less than $50 million in assets from the e-filing requirements, and grant waivers to credit unions that demonstrate substantial core processing or system costs.
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