BSA Forms Mandatory Electronic Filing

On February 24, 2012, FinCEN announced that it is adopting a requirement that all financial institutions subject to Bank Secrecy Act (BSA) reporting use electronic filing for certain reports beginning no later than July 1, 2012. Paper reports filed after that date will be rejected and institutions will be notified and required to re-file an electronic version.

FinCEN has also published notice providing an opportunity for financial institutions to apply for a limited duration hardship exemption that would delay the E-File requirement for certain reports until July 1, 2013.

Financial institutions must file exemption requests with FinCEN by March 26, 2012. FinCEN will consider exemptions for the following circumstances:

1. Institutions lacking internet connectivity,


2. Incompatible system capabilities, or


3. Other extraordinary circumstances.

Detailed information about the new filing requirements and exemption requests may be found here: FinCen Notice