Effective April 1, 2013, all institutions must file the reports electronically.
“If you have any dealings with SARs or CTRs at your credit union, I’d suggest you read through them,” said NAFCU Regulatory Compliance Counsel JiJi Bahhur. “As someone who used to be heavily involved in filling out and filing CTRs and SARs, I can say that even I learned a few new things.”
FinCEN’s FAQs include 22 questions for the SAR and 34 questions for the CTR. The CTR page includes some prepared PDF samples of how to correctly file the report.
Issues addressed include whether institutions are expected to complete “non-critical” items, and what to do if an institution’s software doesn’t permit critical items marked with an asterisk to be filled out.
Bahhur addressed those questions and others included in the FAQs in a NAFCU Compliance Blog item posted Wednesday.