The Financial Crimes Enforcement Network (FinCEN) recently announced system enhancements to the Batch Validation process of the Bank Secrecy Act Electronic Filing System (BSA E-Filing). These enhancements will provide detailed error notifications to credit unions using the BSA E-filing system to submit batch BSA filings.1 These enhancements will take effect November 15, 2008.
The new Batch Validation process will apply to the Currency Transaction Report (CTR) and the Designation of Exempt Persons (DEP) forms. All submitted batch BSA filings must meet the formatting requirements defined by FinCEN in the BSA Electronic Filing Requirements for the Currency Transaction Report (CTR) (FinCEN Form 104) and Designation of Exempt Person (DEP) (FinCEN Form 110). This document may be obtained at http://www.fincen.gov/forms/files/e-filing_CTRDEPspecs.pdf (opens new window).
FinCEN has updated the BSA E-filing User Test system with the new Batch Validation System enhancement at http://sdtmut.fincen.treas.gov/ (opens new window). A detailed Questions and Answers document is also provided.
Michael E. Fryzel
1 A batch BSA filing is an electronic file created by a batch file creation software program
(either developed in-house or bought from a third-party vendor). The file typically contains
multiple BSA forms (although it is possible for a batch to contain just one filing).