Dear Board of Directors:
The purpose of this Regulatory Alert is to notify you that the Financial Crimes Enforcement Network (FinCEN) is changing its process for email delivery of 314(a) information. Receipt and timely response to 314(a) requests is required by the U.S.A. Patriot Act.
If your credit union receives 314(a) transmissions via fax, your credit union will continue to receive fax transmissions. No change will occur in the process for fax transmission of 314(a) information.
For credit unions receiving 314(a) transmissions via email, FinCEN will change to a web-based system on March 1, 2005. All credit unions currently receiving email transmissions must register at http://bsaefiling.fincen.treas.gov/Enroll.html (opens new window) to be provided with access to FinCEN's web-based 314(a) secure communication system.
Once registered, credit unions will access and report on 314(a) information using the web-based 314(a) secure communication system. Emails with attached lists of 314(a) information will no longer be sent to credit unions. Therefore, to comply with 314(a) provisions, credit unions must either use the web-based system or receive 314(a) requests via fax.
All credit unions receiving email transmissions should register on the web-based 314a secure communication system before March 1, 2005.
Information about the registration process was provided via email to credit union primary points of contact by FinCEN on January 28, 2005. Subsequent guidance on the upcoming conversion to a web-based system and the establishment of user accounts may be found on FinCEN’s Web site, http://bsaefiling.fincen.treas.gov/tour/tour.html (opens new window)
On February 22, 2005, NCUA will provide both the primary and secondary U.S.A. Patriot Act contacts reported on the December 2004 call report to FinCEN. Currently, only primary points of contact are provided. Starting the week of February 28, 2005, credit unions should be able to establish user accounts for both primary and secondary points of contact reported on the December 2004 call report.
NCUA is providing the attached list of questions and answers. These questions reflect common inquiries by credit union staff members, involved with the receipt and review of 314(a) information.
If you have questions, please contact FinCEN, the appropriate NCUA regional office, or your state regulator.