Credit Unions Must E-file BSA Forms by July 1

The Financial Crimes Enforcement Network (FinCEN) will require almost all Bank Secrecy Act (BSA) reports to be e-filed as of July 1. Currency Transaction Reports (CTRs), Designations of Exempt Persons, and Suspicious Activity Reports (SARs) are among the reports that can be e-filed, but some reports, such as the Currency and Monetary Instrument Report, are not covered under the e-filing requirement.

According to FinCEN, the switch to all-electronic BSA filing will help speed up financial crime investigations, 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.

According to a frequently asked questions document on FinCEN’s website, it may impose a civil money penalty for paper forms filed after July 1.

There are, however, a few exceptions available. If a credit union is small and/or does not have internet connectivity and files only a few BSA reports, it may have been granted a temporary exception from the e-filing requirements lasting until March 31, 2013.

Some credit unions that have the technical ability to e-file BSA CTRs 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 expire on Dec. 31, according to FinCEN.

The agency has released numerous resources on e-filing including an archived webinar about getting started, a frequently asked questions document, and a tour of the e-filing system.


Questions? Contact the Compliance Hotline: 1.800.546.4465, compliance@nwcua.org.

Posted in Compliance, Marketing & Communications, NWCUA.