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Implementing the New CTR and SAR

Implementing the New CTR and SAR Manual


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Item: M-SAR
Price: $75/$60
 

DESCRIPTION:

The deadline is March 31, 2013.* By this date all financial institutions must implement and electronically file the new FinCEN Form 111 “BSA-SAR” and Form 112 “BSA-CTR.” HOWEVER, these are no longer merely “forms.” They are electronic data collection devices that contain many entirely new data fields (enough to generate over 130 possible error codes!). Decisions you make today will have significant consequences for your institution for years to come.

This manual provides a comprehensive analysis and review of the new CTR and SAR. Emphasis will be placed on identifying the operational and training issues that financial institutions must address to integrate the new forms with existing procedures and processes. To further enhance understanding, numerous examples will be furnished illustrating the completion of the forms using a variety of transaction scenarios.

In addition to providing essential information, this program will also address the inevitable “learning curve” the industry and the regulators experience whenever a critical form is substantially modified. It is predictable that as financial institutions transition to the new forms, unexpected issues and problems will arise. According to FinCEN:

“…FinCEN recognizes that it may need to develop further guidance regarding the filing of the new reports to address additional questions. FinCEN will develop any future guidance through continued dialogue with the industry, law enforcement and regulatory communities.”

This manual is an excellent resource for future reference. 

*Not to be confused with the July 1, 2012 deadline for electronic filing in general.

TOPICS

The New FinCEN Currency Transaction Report (CTR)

  • New information requirements
  • Shortened deadlines for filing
  • Impact of NAICS codes
  • “Supporting documentation” verses BSA record retention
  • Training needs of frontline personnel
  • Examples of transactions generating CTRs and proper completion of the form

The New FinCEN Suspicious Activity Report (SAR)  

  • New information requirements
  • Current issues in identifying and reporting suspicious activities
  • “Continuing activity” and the SAR
  • Adding “attachments” to the SAR
  • Filing joint SARs
  • Restrictions on the SAR narrative
  • Law enforcement and regulatory agency expectations

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