FinCEN Extends Deadline for Adopting New CTRs, SARs
Financial Crimes Enforcement Network (FinCEN) has extended the deadline for financial institutions to use the agency’s new Currency Transaction Reports (CTR) and Suspicious Activity Reports (SAR) to March 31, 2013.
FinCEN extended the deadline partly in response to industry concern about having sufficient time to transition to the new reports and to make necessary changes to internal processes and/or information technology systems. FinCEN had proposed financial institutions implement the new reports by June 30, 2012, the same date proposed for ending the paper-filing option for FinCEN forms. FinCEN expects this extended time frame for incorporating the new CTR and SAR to ease the industry’s transition to these new reports.
FAQs on Interest-Rate Risk Management
The Federal Financial Institutions Examination Council (FFIEC) agencies released answers to frequently asked questions (FAQs) about the January 2010 advisory on interest-rate risk management.
The FAQs respond to common questions critical to sound interest-rate risk management, including appropriate measurement and reporting, robust and meaningful stress testing, assumption development reflecting the institution’s experience, and comprehensive model validation.
The FAQs also provide examples of risk management expectations for financial institutions of various interest-rate risk profiles, including how to adjust processes as risks change. Find more information at ncua.gov or www.ffiec.gov.
Q Is the credit union required to file a Suspicious Activity Report (SAR) each time it files a blocking report with the Office of Foreign Assets Control (OFAC)?
A No. Blocking reports filed with OFAC fulfill the Bank Secrecy Act’s requirement to file SARs for such transactions. But there still may be instances where the credit union will have to file reports with both the Financial Crimes Enforcement Network (FinCEN) and OFAC. For example, credit unions are required to file a SAR in addition to the OFAC report if a transaction triggers BSA reporting rules for reasons other than a match on OFAC’s list (e.g., suspected money laundering or identity theft), or if the credit union possesses information not included on the OFAC report that should be filed with FinCEN.
Q Is a credit union required to file both a CTR and a SAR for a suspicious transaction in excess of $10,000 in cash?
A Yes. The Bank Secrecy Act (BSA) requires all financial institutions to file currency transaction reports (CTR) whenever a currency transaction exceeds $10,000. If a currency transaction exceeds $10,000 and is suspicious, the credit union must file both a CTR and a SAR to report the suspicious or criminal aspects of the transaction. If a currency transaction equals or is below $10,000 and is suspicious, the institution should only file a SAR.
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