Credit unions must begin electronically filing (e-filing) Bank Secrecy Act (BSA) reports by July 1, 2012. FinCEN granted a limited number of “temporary exemptions” for institutions that could demonstrate a “substantial hardship” in meeting this deadline.
Small credit unions without Internet connectivity could submit a hardship exemption request (due by March 2012) for additional time to get their systems up to speed. But temporary exemptions won’t extend beyond March 31, 2013.
FinCEN also reminds institutions to use the correct Currency Transaction Report (CTR) and SAR forms; however, this isn’t a mandate to use new forms. FinCEN extended the deadline for using the new CTR and SAR forms to March 31, 2013.