By Gina Ellis, CRCM
FinCEN has announced changes to the CTR filing form and is targeting August 15, 2017 as the date the changed forms will be available for discrete filers. Effective May 31, 2018, the BSA E-filing system will only accept the updated CTR discrete form. If discrete filers have any templates saved with bank information you can continue to use those until May 2018.
Changes are being made to Part I of the form, renaming the description of the person involved in the transaction from “Courier Service (private)” to “Common Carrier”. A checkbox will be added to Part II to indicate “Shared Branching”. “Unknown” is being added as an option to the primary federal regulatory and employer identification number (EIN) fields in Part III of the form. Additions to Part III include a field to indicate the country location and the cash in and out amounts for the transaction locations. A new Part IV section is being added, requiring additional contact information about the institution filing the CTR.
Batch filers will encounter additional changes as the filing format will be switching from an ASCII based fixed length delimited file to an XML based file. FinCEN conducted a webinar June 21, 2017 discussing the technical batch file changes. An XML user guide is available and includes Attachment C-Electronic Filing Instruction beginning on page 80. You can access the guide here: http://bsaefiling.fincen.treas.gov/docs/XMLUserGuide_FinCENCTR.pdf
As always, we are here to help if you have additional questions! Stay connected with us at www.americanbanksystems.com or call us at (405) 607-7000.