BSA E-Filing Now in Effect
CUs using the e-filing system may choose to electronically file either the legacy or new reports until March 31
The Financial Crimes Enforcement Network (FinCEN) granted a very limited number of “temporary exemptions” for institutions that could demonstrate a “substantial hardship” in meeting the July 1, 2012 requirement (for example, small credit unions that lacked Internet connectivity). But these temporary exemptions won’t extend beyond March 31, 2013, the mandatory date when credit unions must use FinCEN’s new Currency Transaction Report and Suspicious Activity Report.
The BSA e-filing system will accept the older forms (referred to as “legacy reports”) until that date. Credit unions using the e-filing system may choose to electronically file either the legacy or new reports, or any combination thereof, until March 31.