Skip to main content

New SAR and CTR Reports Available for E-Filing – Part 2

New SAR and CTR Reports Available for E-Filing – Part 2:
Written by Bernadette Clair, Regulatory Compliance Counsel
Yesterday, we mentioned that the new Currency Transaction Report (CTR) and Suspicious Activity Report (SAR) contain expanded data fields for the collection of additional data elements.  When the new reports were proposed, there were quite a few questions as to whether the changes created new obligations for filing institutions.  FinCEN’s guidance addresses some of these concerns.
Regulatory Expectations.  It should be noted that FinCEN’s guidance states, more than once, that issuance of the new reports is not intended to create new obligations for filing institutions, or change existing requirements or expectations.  FinCEN also says it will continue to work “with supervisory regulatory authorities as part of its ongoing efforts to promote consistent examination of these filing requirements.”
So in theory these new reports should not create additional reporting obligations (besides figuring out how to fill them out).  Maybe that makes compliance folks feel a little better…and maybe not.
Expanded Data Fields.  Some of the changes to the reports include fairly straightforward data.  For example, optional fields for email address, website address, and IP address have been added.  Often this information is included in the narrative; having a specific field just makes it easier for law enforcement to search.
Here are some of the more interesting changes that caught my eye.
  • Gender:  Gender has been added to the report because it can be an important characteristic for query purposes.  The field is not mandatory and credit unions are not expected to collect gender information – however, credit unions are expected to complete those fields for which they have relevant information.
  • Characterization of Suspicious Activity:  FinCEN has added additional data elements for characterizing the suspicious activity and types of financial services involved.  Aside from critical fields (that must be completed) these additional fields are designed to efficiently bring information about suspicious activity to FinCEN’s and law enforcement’s attention.  The expanded choices do not require the credit union to determine whether any and/or all of the choices apply to the activity being reported. FinCEN reiterates that institutions are not responsible for investigating the underlying suspected crime, but for reporting the information they know at the time they conclude that suspicious activity is present.  Investigations remain the responsibility of law enforcement.
  • Spreadsheet attachment:  How many times have we been told not to include attachments when filing SARs?  Well, the tune is changing just a bit.  Now, credit unions can include a single, comma separated value (CSV) attachment as part of the report. The purpose is to include tabular data which is more readable and usable in this format than it would be if otherwise included in the narrative. The attachment would be considered part of the narrative. 
See FinCEN’s guidance for further information on filing the new reports and the expanded data fields.
Well, I think that’s enough for one day.  Happy Friday!

Comments

Popular posts from this blog

NCOFCU Newsletter

The Bucket Coach is a financial advice book designed by Fire Services Credit Union, Tronto, Canada. and written exclusively for Fire Fighters It's a practical guide for household financial management, including investments, credit and mortgages, and retirement. Developed with contributions from Fire Fighters," NCOFCU Newsletter : " Kevin Connolly Chief Executive Officer    Fire Services Credit Union Phone: 416-440-1294 ext 301  Toll Free: 1-866-833-3285 E-mail:  kevin@firecreditunion.ca 1997 Avenue Rd Toronto, ON M5M 4A3 

CUNorthwest Todd A. Powell Award is SFCU CEO Gayle Furness.

Spokane Firefighters Credit Union Big Enough to Serve. Small Enough to Care. This year’s recipient of the CUNorthwest Todd A. Powell Award is SFCU CEO Gayle Furness. Like Todd, Gayle has been instrumental in the growth, as well as the safety and soundness, of the credit union. Congrats to Gayle for living up to the standard that Todd created for our organization and the greater credit union community. __ ________________________________ Check out NCOFCU's additional features: First Responder Credit Union Academy Podcasts YouTube Mini's Blog Job Board

The Shrinking Pool of Small Credit Unions: Why It Matters & What We Can Do About It. - Henry Meier, Esq.

  Henry Meier, Esq. Henry Meier is the former General Counsel of the New York Credit Union Association, where he authored the popular New York State of Mind blog. He now provides legal advice to credit unions on a broad range of legal, regulatory and legislative issues. He can be reached at (518) 223-5126 or via email at  henrymeieresq@outlook.com . For as long as I’ve been around the industry, I’ve heard concerns about the demise of the small credit union. But I’ve come to realize it’s a lot like the weather: Everyone talks about it, but no one does anything about it. This is unfortunate. We need credit unions of all shapes and sizes to survive, and if we don’t take action soon, it will be too late.  Fortunately, there are steps the industry can take to potentially decrease the rate at which small credit unions are disappearing by making it viable for credit unions to survive by getting larger credit unions interested in making the necessary investments to keep the sma...

What Are Your Plans -As Government Shutdown Continues, Credit Unions Expand Offers of Assistance

BILOXI, Miss.— With the federal government shutdown now entering its second week, an increasing number of credit unions across the country are offering relief and financial assistance. All indications are the shutdown is no closer to ending than it has been since it began on Oct. 1. While the House has passsed a continuing resolution (CR) to fund government operations in the short term, the Senate remains at an impasse, even as it has scheduled a vote for today. In addition to the earlier assistance reported by the CU Daily  here , the latest pledges to support members include: • In Biloxi, Miss., Keesler FCU said it is offering paycheck relief for all eligible federal employees affected by the shutdown and will advance the amount of direct deposit paychecks for eligible members during the shutdown for up to 90 days. There is no cost or fee to enroll in the program. • In Nebraska, Cobalt Credit Union is offering furloughed members loans of up to $5,000 with no fees or interest...

Sunday Reading - FIRE, 101 - “financial independence, retire early,”

  Retiring at 30     FIRE, 101 Most US workers aim to retire around age 65—but for many followers of the FIRE movement, which stands for “ financial independence, retire early ,” that’s not the case. FIRE followers, who range from low- to high-income workers, typically prioritize high savings rates, relatively frugal living, and aggressive investing strategies in an effort to work less and enjoy life more in the long-term ( see five distinct approaches ). While many proponents argue that the movement is more of a mindset about achieving financial freedom than any ...