On February 23, 2012, FinCEN released a final notice requiring credit unions to electronically file all CTRs and SARs by July 1, 2012. In addition FinCEN provides a process for credit unions to apply for a hardship exemption. FinCEN will consider exemptions for (1) small credit unions lacking internet connectivity (2) major system conversion to enable batch and computer-to-computer CTR filing or (3) other extraordinary circumstances. The League InfoSight’s Newsletter provides additional information on the final notice and applying for an exemption.
Dates to remember:
- March 26, 2012: deadline for requesting an exemption from mandatory filing;
- July 1, 2012: mandatory efiling of CTR’s and SARs unless granted an exemption; March 13, 2013: deadline for credit unions already filing electronically to begin using new CTR and SAR forms;
- March 31, 2013: every credit union must be efiling their BSA forms