User Manual

Financial Crimes Enforcement Network

Version 3.8 – July 2011

BSA E-Filing System User Manual

This document is intended to assist users of the BSA E-Fil ing System. I t may not be used for any other purpose or re-disseminated to any other person or entity without the express permission of the Financial Crimes Enforcement Network of the U.S. Department of the Treasury.

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Table of Contents

1. THE PURPOSE OF THIS MANUAL 1-11.1 What information is contained in this document? 1-1

1.2 Who should use this manual? 1-2

2. USING BSA E-FILING 2-12.1 BSA E-Filing Overview 2-1

2.1.1 BSA E-Filing and BSA Requirements 2-2

2.2 What is needed to Connect to BSA E-Filing? 2-2

2.2.1 Batch Filing Considerations 2-3

2.2.2 Acceptable Format of Files Submitted Through BSA E-Filing 2-3

2.2.3 Size of Batch Files Accepted by BSA E-Filing 2-4

3. BSA E-FILING USER IDS, PASSWORDS AND PINS 3-13.1 What Is A user ID, Password, and PIN? 3-1

3.2 Who needs a user ID, Password, and PIN? 3-1

3.3 Responsibility of user ID, Password, and PIN Possession 3-3

4. DOWNLOADING ADOBE READER 4-15. ACCESSING BSA E-FILING 5-1

5.1 Obtaining BSA E-Filing Role(s) and Privileges(s) 5-1

5.2 Logging on to BSA E-Filing 5-1

5.3 Logging off BSA E-Filing 5-1

6. FILING THROUGH BSA E-FILING 6-16.1 Methods of Filing 6-2

6.2 Discrete Filing of BSA Forms 6-2

6.3 Batch Filing of BSA Forms 6-16

6.4 Downloading Batch Files with BSA Electronic Filing Requirements 6-17

6.4.1 Requirements for ASCII CTR Batch Files 6-17


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6.4.2 Requirements for EBCDIC CTR Batch Files 6-17

6.4.3 Considerations for Batch File Download from Mainframe 6-18

6.5 Submit CTR/DEP Batch File on the BSA E-Filing System 6-19

6.6 Opening a Saved CTR/DEP Batch Information Form and Unsigning a Form 6-27

6.7 Track the Status of Filings 6-31

6.8 Accessing Acknowledgements 6-37

6.8.1 Acknowledgement Email Notification 6-37

6.8.2 Accessing Acknowledgements 6-39

6.8.3 Storing Acknowledgements for Your Records 6-42

6.8.4 Considerations for Acknowledgement File Upload to Mainframe 6-42

6.8.5 Taking Corrective Action in Response to Negative Acknowledgements for CTR, CTR-C or DEP Filings 6-43

6.9 Amending or Correcting Previously Submitted Filings 6-45

6.9.1 Submitting an Amended Discrete Type of CTR 6-45

6.9.2 Submitting a Corrected Discrete SAR Type Filing 6-46

6.9.3 Submitting CTR/DEP or SAR Batch Amendments or Corrections 6-47

6.9.4 Submitting CTR/DEP Batch Filings with Override Option 6-47

6.10 BSA E-Filing Administrative Data Retention Policy 6-50

7. ALERTS 7-17.1 Accessing Alerts 7-1

8. SECURE MESSAGING 8-18.1 Creating and Sending a Secure Message 8-1

8.2 Viewing All Sent Messages 8-4

8.3 Receiving a Secure Message Reply 8-5

8.4 Accessing a Secure Message Reply 8-5

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9. GETTING HELP FOR BSA E-FILING 9-19.1 BSA E-Filing System User Manual 9-1

9.2 Supervisory User Manual 9-1

9.3 Computer-Based Training Module 9-1

9.4 Quick Reference Guide 9-2

9.5 Frequently Asked Questions 9-2

9.6 Contacting the BSA E-Filing Help Desk 9-2

10. TIPS FOR USING BSA E-FILING 10-110.1 Reducing Form Preparation Time 10-4

10.2 Determining the Number of Required BSA E-Filing Users in Your Organization 10-6

10.3 Streamlining Batch File Upload Processes 10-7

10.4 Filing Naming Conventions and Local Directory Storage 10-8

10.5 Branch Code Naming Conventions 10-9


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List of Figures

Figure 2.1-1. BSA E-Filing Process Overview 2-1

Figure 3.2-1 Who Needs A User ID, Password, and PIN 3-2

Figure 3.3-1. BSA E-Filing Change Password Request 3-4

Figure 3.3-2. BSA E-Filing Request for New Password 3-4

Figure 4-1. BSA E-Filing System Homepage 4-1

Figure 4-2. Adobe Reader Software Download 4-2

Figure 5-1. Log Off Button 5-2

Figure 6-1. User Roles 6-1

Figure 6.2-1. BSA E-Filing System Homepage for Enrolled Users 6-3

Figure 6.2-2. Open a Form Page Window 6-4

Figure 6.2-3. Submission Type Field 6-5

Figure 6.2-4. Currency Transaction Report Screen 6-6

Figure 6.2-5. Multiple Person / Multiple Transaction Checkboxes 6-7

Figure 6.2-6. Add/Edit Additional Accounts 6-7

Figure 6.2-7. Validate Button 6-8

Figure 6.2-8. Sign with PIN Button 6-8

Figure 6.2-9. Form Signed with PIN Button 6-8

Figure 6.2-10. Save Button 6-9

Figure 6.2-11. Save Form Specify Filename Window 6-10

Figure 6.2-12. Validation Error Window 6-10

Figure 6.2-13. Choose File Window 6-11

Figure 6.2-14. Remove Signature Button 6-12

Figure 6.2-15. Print Window 6-13

Figure 6.2-16. Submit Button 6-13

Figure 6.2-17. Confirmation Page Window 6-15


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Figure 6.5-1. Open Form Page Window 6-20

Figure 6.5-2. BSA E-Filing CTR / DEP Batch Form Page 6-21

Figure 6.5-3. Add Attachment Button 6-22

Figure 6.5-4. Select a data file to import Window 6-23

Figure 6.5-5. Attachment Warning Window 6-23

Figure 6.5-6. Title Field 6-24

Figure 6.5-7. BSA E-Filing CTR / DEP Batch Form Page 6-25

Figure 6.5-8. Sign with PIN Button 6-26

Figure 6.5-9. Save Button 6-26

Figure 6.5-10. Submit Button 6-27

Figure 6.6-1. Choose File Window 6-28

Figure 6.6-2. Remove Signature Button 6-28

Figure 6.6-3. Confirmation Page Window 6-29

Figure 6.7-1. Track Status Screen 6-31

Figure 6.7-2. Submission Warnings Page 6-32

Figure 6.7-3. Download as XML Page 6-33

Figure 6.7-4. Submission Errors Window 6-35

Figure 6.7-5. Acknowledge Error Codes Window 6-36

Figure 6.8-1. View Inbox Screen 6-39

Figure 6.8-2. Secure Message Reply Form Window 6-40

Figure 6.8-3. Secure Message Reply Form 6-41

Figure 6.9.4-1. BSA E-Filing CTR / DEP Batch Form with Overrides Rejected 6-48

Figure 6.9.4-2 Batch Form with Override (filled out) 6-49

Figure 6.10-1. Administrative Data Retention Policy Table 6-50

Figure 7.1-1. View Alerts Screen 7-2

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Figure 7.1-2. Alert Form Window 7-3

Figure 7.1-3. View Attachment Button 7-4

Figure 7.1-4. Attachments Window 7-4

Figure 7.1-5. File Download Box 7-5

Figure 8.1-1. Secure Message Form Window 8-2

Figure 8.1-2. Select a data file import 8-3

Figure 8.2-1. View Outbox Screen 8-4

Figure 8.4-1. View Inbox Screen 8-5

Figure 8.4-2. Secure Message Reply Form Window 8-6

Figure 8.4-3. View / Save Attachment 8-7

Figure 8.4-4. Attachment Window 8-7

Figure 8.4-5. File Download Box 8-8

Figure 8.4-6. Open File Window 8-8

Figure 10-1. Legend for Main Street Bank 10-2

Figure 10-2. BSA E-Filing Forms Process 10-3

Figure 10.1-1. Pre-populated Form Template 10-4

Figure 10.1-2. Pre-populated Form Template 10-5

Figure 10.2-1. Centralization Example 10-7

Figure 10.4-1. BSA E-Filing Header 10-8

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REVISION HISTORY

Version Number Date Reason for Change2.0 10/01/02 Initial Issue

2.1 4/7/08 Removed State and Country list. Removed ZIP Code validation list. Both lists may be accessed at www.fincen.gov/reg_bsaforms.html

3.0 7/19/08 Replaces references •to magnetic media with referencestoelectronicfilingusing the BSA E-Filing System.

Removed description of use of •certificates.

Updatedtoreflectchangeto•web site.

3.1 11/08 Updatedtoreflecttheimplementation of Batch Validation

3.2 6/09 Updated to include transition to Adobe Reader, remove option for “correction” on a CTR, log off button,limitationonbatchfilesize

3.3 9/09 UpdatedtoreflectintroductionofSAR acknowledgements

3.4 12/09 UpdatedtoreflectintroductionofSAR validations

3.5 01/10 Updatedtoreflectfilteredviewof Track Status and View Inbox

3.6 5/10 Removed all references to supported Adobe Reader versions and replaced with a link to the public website that provides the supported Adobe versions:

http://bsaefiling.fincen.treas.gov/Enroll_Now_Step_04.html


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REVISION HISTORY

Version Number Date Reason for Change3.7 07/10 Updated BSA E-Filing Help

Desk toll free phone number and the BSA E-Filing email address

3.8 7.11 Section 3.3: Updated to •reflectnewpolicyregardingunsuccessful attempts to answer challenge phrase, as well as new password changerequestnotification.

Section 6: Updated to •include new form types RMSB and FBAR.

Section 6.2: Updated to •reflectnewInvalidPINprocess.

Section 6.7: Updated •to include updates to Track Status ‘Submission Warnings’ table.


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Please note that the term “discrete filing” refers to BSA forms that are submitted one at a time and not 1. in aggregated batches.

1. The Purpose of this ManualThis manual provides the user of the BSA E-Filing System with the information necessary to use the system for filing Bank Secrecy Act (BSA) forms, receiving Alerts, and engaging in Secure Messaging with FinCEN. This manual is a key component of the BSA E-Filing training curriculum, which includes additional documentation (such as the Supervisory User Manual and the Quick Reference Guide), on-line computer-based training, and technical assistance from the BSA E-Filing Help Desk (instructions for obtaining technical support are in Section 9 of this document). Please note that this manual does not attempt to provide any Bank Secrecy Act (BSA) compliance recommendations or guidance.

1.1 What information is contained in this document?

This manual contains procedural and technical information related to BSA E-Filing. Its essential contents include:

Getting Started - What you need to know and do before using BSA E-Filing □

How to Enroll in BSA E-Filing □

How to file BSA forms discretely □ 1 via BSA E-Filing

How to file BSA forms in batches via BSA E-Filing □

How to receive Alerts from FinCEN via BSA E-Filing □

How to use the BSA E-Filing Secure Messaging functionality □

Instructions in this manual, including screen shots, apply to Internet Explorer.

Note that Supervisory Users can download the Supervisory User Manual from the BSA E-Filing site. The Supervisory User Manual contains details pertaining specifically to the responsibility of Supervisory Users. A Supervisory User has privileges to request user IDs for new users within their filing organization, assign BSA E-Filing roles to enrolled users, track all filings submitted by all users within their organization, and delete users from their organization.


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1.2 Who should use this manual?

This manual is for BSA E-Filing users only. This includes all individuals in filing organizations that will interact directly with the BSA E-Filing site or BSA E-Filing electronic filing forms. These individuals include filers, reviewers, submitters of filings, and filing organization Supervisory Users. Supervisory Users should also consult the Supervisory User Manual for processes that pertain specifically to Supervisory Users. This manual is not for distribution beyond this specified group. Updated versions of this document will be made available periodically as new enhancements and capabilities are added to the site. Subsequent versions of this manual will be available on the secure portion of BSA E-Filing by clicking on the ‘User Manual’ link on the left navigation menu. It is a good practice to periodically check the version available on BSA E-Filing to ensure that you have the most up-to-date version on hand.

Note: Throughout this manual you will occasionally see shaded text boxes (such as this one) containing bold and italicized text. Pay special attention to the information in these boxes as it is critical to proper BSA E-Filing use and security.


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2. Using BSA E-FilingThis section provides the information that you will need to prepare yourself, your organization, and your systems for using BSA E-Filing.

2.1 BSA E-Filing Overview

BSA E-Filing functionality allows:

Filing organizations to electronically file and track discrete and batched BSA 1. forms in a highly secure fashion over the Internet.

FinCEN to issue Alerts containing FinCEN advisories and system updates.2.

Filing organizations to send Secure Messages to FinCEN (and receive responses 3. where appropriate) in response to Alerts.

Figure 2.1-1. BSA E-Filing Process Overview


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2.1.1 BSA E-Filing and BSA Requirements

BSA E-Filing is an additional channel for organizations to submit BSA filings. The development and availability of BSA E-Filing does not in any way affect the requirements of the Bank Secrecy Act or the BSA compliance guidelines under which your organization is currently operating. Direct any questions regarding BSA requirements to your organization’s chief compliance officer or the FinCEN BSA Regulatory Helpline at 800-949-2732.

2.2 What is needed to Connect to BSA E-Filing?

BSA E-Filing is a secure Internet-based application that you can access with the appropriate credentials (see Section 3.0 BSA E-Filing user ID, Passwords, and PINs). To connect to BSA E-Filing, your organization will need:

At least one computer terminal that has access to your Internet connection and • meets the following specifications:

Intel Pentium III or greater processor □

At least 128 MB RAM (256 MB recommended) □

200 MB of free disk space □

Microsoft Windows 2000, with Service Pack 4; Windows Server 2003; □Windows XP Professional or Home Edition with Service Pack 2 or 3

Web browser: □

Must have 128-bit encryption Ň

Check the encryption level of Internet Explorer browsers by clicking on »‘Help > About Internet Explorer,’ and then ‘About.’ Review the ‘Cipher Strength’ for bit encryption

I Ň nternet Explorer 6.0 or higher

You cannot access BSA E-Filing using the Apple platform Ň

You cannot access BSA E-Filing using the Firefox browser at this time Ň


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Your organization’s firewall must permit access through port 443 for the Secure • Sockets Layer (SSL) protocol. (SSLv3 is used to encrypt all data submitted to BSA E-Filing).

You will also need to acquire user IDs for all users that will directly access BSA • E-Filing. The use of user IDs for BSA E-Filing ensures that an individual has the proper authority to access and use BSA E-Filing. User IDs are provided free of charge to BSA E-Filing users.

You will need to install the compatible version of Adobe Reader on your • computer to use BSA E-Filing. Please review the details of how to obtain Adobe Reader in Section 4.0 Downloading Adobe Reader. Contact your system administrator if you have questions regarding your computer configuration.

2.2.1 Batch Filing Considerations

BSA E-Filing users that will be filing batches must meet the same technical requirements as those that will be filing discrete BSA forms. Additional considerations include:

Batch file size: Batch files are typically large, making increased bandwidth (i.e., • Internet connectivity speed) desirable, but not required for batch filers.

Linkage between your batch file creation systems and the Internet: The • computer terminal(s) that will be used to upload batches of BSA filings via BSA E-Filing must have ready-access to the batch files, either via electronic link to the batch file creation systems or a common network drive.

2.2.2 Acceptable Format of Files Submitted Through BSA E-Filing

Discrete filing2 : Use BSA E-Filing Adobe Reader e-forms to submit forms to the system

Again, please note that the term “discrete filing” refers to BSA forms that are submitted one at a time 2. and not in aggregated batches.


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Batch filing: You can submit batch files in either ASCII or EBCDIC format. Batch file information, content, and organization should conform precisely to the guidelines for electronic filing detailed in the appropriate BSA E-Filing Electronic Filing requirement documents:

BSA E-Filing Electronic Filing Requirements For The Currency Transaction • Report (FinCEN Form 104) And Designation Of Exempt Person (FinCEN Form 110)

BSA E-Filing Electronic Filing Requirements of Suspicious Activity Reports By • Depository Institutions (SAR-DI)

BSA E-Filing Electronic Filing Requirements For Suspicious Activity Report By • Money Services Business (SAR-MSB)

BSA E-Filing Electronic Filing Requirements For Suspicious Activity Reports By • The Securities and Futures Industries (SAR-SF)

BSA E-Filing Electronic Filing Requirements For The Casinos and Card Clubs • Suspicious Activity Reports (SAR-C)

BSA E-Filing Electronic Filing Requirements For The Currency Transaction • Report By Casinos (CTR-C)

Note: The requirements documents listed above are available on the FinCEN website (www.fincen.gov) by clicking on ‘Forms > E-Filing Specifications’.

Please see ‘Downloading Batch Files with BSA E-Filing Electronic Filing Requirements’ located in Section 6.4 for details regarding how to ensure batches are maintained in a format acceptable by FinCEN during downloads from your organization’s mainframe to your BSA E-Filing connected personal computer.

2.2.3 Size of Batch Files Accepted by BSA E-Filing

The maximum acceptable size of a batch file is 60 MBs (this applies to all BSA batch files of either EBCDIC or ASCII format). BSA E-Filing will not accept compressed files. BSA E-Filing will automatically compress files during the submission process. Decompress or unzip any compressed (or “zipped”) files before submitting them to BSA E-Filing.


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3. BSA E-Filing user IDs, Passwords and PINs

This section describes the BSA E-Filing user ID and password, who needs a user ID and password, and associated responsibility.

3.1 What is a user ID, Password, and PIN?

A user ID and password are a pair of character strings used to identify and authenticate a user to the BSA E-Filing System. They are composed of letters, numbers, and selected special characters. User IDs are not case sensitive. Passwords are case sensitive. A user ID and password establishes and authenticates your identity to perform functions on the BSA E-Filing system. They are issued by the BSA system. An 8-digit Personal Identification Number (PIN) is associated with each user ID/password pair. The PIN provides technical non-repudiation of submissions.

3.2 Who needs a user ID, Password, and PIN?

The table one the following page provides examples of who does and does not need a user ID, password, and PIN within a filing organization. As a general rule, anyone who needs to sign forms or interact with the BSA E-Filing website (i.e., to submit forms, view Alerts, or send Secure Messages) will require a user ID, password, and PIN. If a user simply wants to complete or view BSA forms; they only need the Adobe Reader software and the BSA forms installed on their workstation. Note: a single person may perform several of the functions described in the table:


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Staff Role Description Require user ID?BSA E-Filing Manager (Supervisory User)

The person who will oversee the filingorganization’suse of BSA E-Filing.

Yes. This person will be responsible for enrolling their filingorganizationinBSAE-Filing,grantingprivilegesto their users, and managing their FO’s use of BSA E-Filing on an enterprise basis. Therefore they must have a user ID and password so that BSA E-Filing can identify them as a valid user.

Form Creator A person who isfillingoutBSA forms but NOTsigningorsubmitting them.

No.ThispersoncancreateBSAFilingsbyusingtheAdobe Reader software and sending them to a “Form Signer” or “Form Submitter” within their organization viaemailorsomeotherinternalmethodoffilesharing. This person must have the Adobe Reader software as well as the BSA Adobe Reader e-forms stored on their workstation. Example: Tellers A, B, and C each create 10 BSA forms in a given business day using the Adobe Reader e-forms and Adobe Reader software they have stored on their computers. They email these BSAformstotheirComplianceOfficerwhosignsand submits them through BSA E-Filing. Only the ComplianceOfficerneedsauserID,password,andPIN;theFormCreators(tellersA,B,andC)donotneedauserID,password,andPIN.

Form Signer A person who digitally signs single BSA forms.

Yes. This person will require a user ID, password, andPIN.

Form Submitter

A person who uses BSA E-Filing to submit BSA forms.

Yes. If a person’s role is to submit forms to BSA E-Filing, they will require a user ID, password and PINsothatBSAE-Filingcanidentifythemasavaliduser.

Figure 3.2-1. Who Needs A User ID, Password, and PIN


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3.3 Responsibility of user ID, Password, and PIN Possession

Users are responsible for maintaining control over their user ID, password, and PIN. They may not be shared with non-BSA users or with other BSA users. They uniquely identify and authenticate a single user to the BSA system and their use implies that the specific user they were issued to is the one using them.

If a password or PIN is compromised, the user should immediately use the BSA system to generate a new password or PIN. A new password may be generated by connecting to the BSA site, selecting “E-Filing System Login”, “I Agree”, entering the user’s user ID, clicking on “Change Password” or “New Password.”

When the user clicks on “Change Password”, the user must enter the current password and the new password. The password restrictions must be met or the password will be rejected.

When the user clicks on “New Password”, the user’s challenge phrase is presented and the user must supply the correct answer. The system generates a temporary password and sends it to the user via email. If the user enters an incorrect challenge phrase answer, an error message will appear prompting the user to re-enter their ‘Challenge Phase’ answer. Three unsuccessful attempts to provide the correct challenge phrase answer will result in the deactivation (i.e. “locking”) of the user’s account. If your account is deactivated for this reason, you must contact the BSA E-Filing Help Desk for assistance.


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Note: Users will be forced to change their password every 30 days from the initial date of creation.

Figure 3.3-1. BSA E-Fil ing Change Password Request

Figure 3.3-2. BSA E-Fil ing Request for New Password


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When the filer has successfully updated (i.e. changed) the password associated with their BSA E-Filing account, the system will display a message informing the filer that their password has been changed (see Figure 3.3-3). Click OK in order to access the Welcome to the BSA E-Filing System page.

Figure 3.3-2. BSA E-Filing Request for New Password


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4. Downloading Adobe Reader

If you have not already installed the Adobe Reader software on your computer, you will be able to download Adobe Reader from the BSA E-Filing site. Adobe Reader allows you to view and prepare electronic BSA forms on BSA E-Filing, view BSA E-Filing Alerts, and create Secure Messages to send to FinCEN.

Selecting the download option: Click on the 1. Downloading the Forms Viewer link on the BSA E-Filing System Homepage (shown in the following graphic).

Figure 4-1. BSA E-Filing System Homepage


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2. Review Adobe Reader instructional page: Click Adobe Website link to be directed to the Adobe Website to download the Adobe Reader to initiate the download.

Figure 4-2. Adobe Reader Software Download


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To determine if a particular version of Adobe Reader is installed on your computer, follow these instructions:

1. Go to your Start Menu.

2. Select Settings and then Control Panel.

3. In the Control Panel window, select Add or Remove Programs.

4. A list of your currently installed programs will be displayed.

5. If you see the Adobe Reader version supported by the BSA E-Filing system in the list, you have the required software.

If you do not have this software or specific version on your computer, you may download it for free directly from the Adobe Web site: http://get.adobe.com/reader/ or through FinCEN’s Web site at http://www.fincen.gov/forms/bsa_forms/ and click on the link under Forms.

Follow the instructions below to complete the download:

1. Go to http://get.adobe.com/reader/otherversions/

2. Select your Operating System from the drop-down box. If you do not know what Operating System you have, you may find it by following these steps:

• Go to your Start Menu.

• Select Settings and then Control Panel.

• In the Control Panel window, select System.

• Your System Properties will be displayed within the General tab selected.

• You will find your Operating System information there.

NOTE: If you are unable to download or install the Adobe Reader, check with your system administrator to make sure that you have the security permissions to install new programs on your system.

NOTE: The required versions of Adobe Reader for the BSA E-Filing system are located at the top of the Download the Forms Viewer page.


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3. Select your Language (English, Spanish, etc).

4. Press “Continue”.

5. The available versions of the Adobe Reader will be displayed.

6. Select the Adobe Reader version supported by the BSA E-Filing system and press the “Download” button

7. Follow the instructions provided by Adobe to complete your download.

NOTE: Other Adobe applications such as Acrobat/AIR have been proven to override Adobe Reader settings with varying results. If possible, these applications should be removed to guarantee functionality with the BSA E-Filing website.


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5. Accessing BSA E-Filing

This section identifies the steps necessary to Login into the BSA E-Filing System.

5.1 Obtaining BSA E-Filing Role(s) and Privileges(s)

Once you have successfully enrolled in BSA E-Filing, you will have no default privileges to use BSA E-Filing functionality (unless you are registered as a Supervisory User or an individual FBAR Filer). If you are a new General User, your Supervisory User must assign roles to you, allowing you to engage in BSA E-Filing functionality as appropriate. For example, filers of discrete CTRs would need access to the ‘File CTR’ and ‘Secure Messaging’. Please contact your Supervisory User to prompt him/her to assign roles to you so that you may begin to use the functions that BSA E-Filing offers.

5.2 Logging on to BSA E-Filing

Perform the following steps to access BSA E-Filing (these steps assume that you have completed the initial enrollment process that is required the first time you log on.)

Launch browser:1. Launch the Microsoft Internet Explorer browser on your computer (see Section 2.2 for browser specifications).

Navigate to the BSA E-Filing website2. : In the URL field, enter the BSA E-Filing Internet address http://bsaefiling.fincen.treas.gov.

Click on3. E-Filing System Login

Select “4. I Agree”

Enter your user ID in the 5. User ID field and enter your password in the Enter Password field and then click the Submit button. Note: Three unsuccessful login attempts due to an invalid password will result in the deactivation (i.e. “locking”) of the user’s account. If your account is deactivated for this reason, you must contact the BSA E-Filing Help Desk at 1-866-346-9478 (option 1) or [email protected].


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5.3 Logging off BSA E-Filing

It is a good practice to always log off BSA E-Filing once you have completed your session. This will prevent unauthorized users from accessing BSA E-Filing at your computer terminal in your absence. To log off BSA E-Filing, click on the “Logoff” button on the top right corner of the BSA E-Filing home page.

Figure 5.1 Log Off Button


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6. Filing through BSA E-Filing

BSA E-Filing is designed to be easy to use despite the significant security requirements surrounding BSA filing processes. Essentially, BSA E-Filing allows filing organizations to do three things:

File BSA Forms1. : Electronically file BSA forms (both individual (discrete) and in batches); receive acknowledgments; and track the submission status of those filings as appropriate.

View Alerts2. : Receive Alerts from FinCEN.

Send Secure Messages3. : Send Secure Messages to FinCEN and receive replies to those messages.

These functions are accessed from the navigation bar on the left side of the BSA E-Filing homepage. Not all users will have access to all BSA E-Filing functionality and not all users will be able to view all of their filing organization’s filings. Supervisory Users will assign roles to their General Users, providing the users with role-based privileges that will provide them with access to specific BSA E-Filing functionality. A user may be provided with any or all of the following roles:

Discrete Filer Roles Batch Filer Roles Additional RolesCTR Filer CTR Batch Filer Secure MessengerCTR-C Filer CTR-C Batch Filer Alerts ReceiverDEP Filer SAR Batch FilerSAR Filer SAR-C Batch FilerSAR-C Filer SAR-SF Batch FilerSAR-SF Filer SAR-MSB Batch FilerSAR-MSB Filer SDTM Batch FilerRMSB FilerFBAR Filer

Figure 6-1. User Roles

Note: A BSA filer enrolled as an individual FBAR Filer will have pre-assigned roles associated with their account. The purpose of registering as an individual FBAR Filer is to report FBAR data to FinCEN on behalf of yourself rather than a business (i.e. institution).





Only a Supervisory User is able to track the filings submitted by other filers within their organization, whereas general users are only able to track the filings they personally submit. Details of how a Supervisory User assigns these roles and privileges are provided in the Supervisory User Manual (available only to Supervisory Users).

To use the system effectively, each filing organization and its users must have a clear understanding of the type of user they are and the types of features they need to use within BSA E-Filing. The following section discusses filing user types, and will assist you in determining what user type applies to you.

6.1 Methods of Filing

Filing Organizations vary in the methods they use to submit BSA filings. At the most basic level, some organizations submit single BSA forms, while others submit an electronic file (batch) containing a group of filings at one time. Thus, given there are different types of filing users for BSA E-Filing, we will profile the various filing user types below so you may determine which filing user type you are and focus on the sections of this manual relevant to your circumstances. Following are the basic types of filing users:

Discrete Filer of BSA Forms:• These users file single BSA forms to FinCEN. Prior to BSA E-Filing, the only ways to file a single BSA form were to either file the BSA on paper or to create an electronic “batch” of one BSA form in the format required by FinCEN.

Batch Filer of BSA Forms:• These users file multiple BSA forms in one electronic batch that meets the requirements outlined in FinCEN’s BSA E-Filing Electronic Filing Requirements.

Note: As you navigate through the filing functions in BSA E-Filing, you will notice that some information fields are pale yellow and aqua in color, while others are simply white in color. The pale yellow colored fields represent information fields that are mandatory for form submission, whereas the aqua colored fields are not mandatory for forms submission but are highly recommended.





6.2 Discrete Filing of BSA Forms

The following example provides the basic steps for filling out, signing, and submitting a discrete CTR. Note that the process for filling out and submitting any discrete BSA form is similar to this example. To file a single CTR, perform the steps below:

1. Select File CTR: Select File CTR from the BSA E-Filing navigation menu on the left side of the BSA E-Filing System homepage on the secure site, accessible only to BSA E-Filing users (see Figure 6.2-1).

Figure 6.2-1. BSA E-Filing System Homepage for Enrolled Users

2. Select Open New Form: After clicking on File CTR, the Open a Form page will appear (see Figure 6.2-2). From this page you may click on Open New Form to open a new CTR form. The first page that you will see is the BSA E-Filing Currency Transaction Report Header. You may also retrieve any form that you have previously created and saved locally. That process will be discussed in Step 11, Open a Saved CTR form





Figure 6.2-2. Open a Form Page Window

3. Enter a CTR Filing Name: On the BSA E-Filing Currency Transaction Report Header page, enter a unique name for the filing in the Filing Name field. This is a required field. A unique name will allow you to distinguish each filing. Please utilize naming conventions that will assist you in identifying the filing for tracking purposes. For example, you may consider using the date as part of the filing name (e.g. 05282002CTR1).

Note: The Track Status portion of BSA E-Filing lists the Filing Name and status of each discrete CTR you have submitted.

4. Select Resolution Code: Select the appropriate Resolution Code. The options are either Parent Financial Institution or Branch Financial Institution from the drop-down box. The resolution code determines where FinCEN will refer issues, if necessary, related to the content of the filing. This is not a required field.





5. Enter a Branch Code: Enter your Branch Code (see Section 10.5 for tips on Branch Code Naming Conventions). If your organization does not submit all CTRs from one central submission point, this field allows you to record the branch that submitted the CTR. Note this is not a required field, so you do not have to enter a branch code if you do not have one.

6. Select Submission Type: Select an option from the Submission Type drop-down box. The options are: New (for original filings) or Amendment (for making amendments to a previously filed form), from the drop-down box (see Figure 6.2-3). Please refer to Section 6.9 Amending or Correcting Previously Submitted Filings for additional details about submitting such a filing.

Figure 6.2-3. Submission Type Field

7. Enter a DCN, if applicable: If this is an original filing, then leave this field blank. If the filing is an amendment to a previous filing, you must enter the Document Control Number that you received in your Acknowledgement file from FinCEN. If you are submitting an amended filing, please refer to Section 6.9 Amending or Correcting Previously Submitted Filings for additional details about submitting such a filing.





Figure 6.2-4. Currency Transaction Report Screen





Important Note: There are instructions available for each field on the CTR form. To view these instructions, move your cursor over the field in question. These instructions are the same as the CTR paper form for content and include guidelines for acceptable format of the content as specified by FinCEN. Any field highlighted in yellow is a required field. You must enter information in these fields before you can submit the form to BSA E-Filing. Fields highlighted in aqua are recommended but not required for form submission.

8. Complete CTR form: The electronic CTR form requires the same information as is required by the existing CTR paper form (FinCEN Form 104). All the electronic BSA forms require the same information as required by their existing paper counterparts. You can navigate through the BSA E-Filing CTR electronic form by using the Tab key to move between adjacent fields or by moving your mouse cursor to a desired field. If there are multiple persons involved with the transaction being reported or if multiple transactions are involved, you must select the Multiple Persons and/or Multiple Transactions check boxes respectively (see Figure 6.2-5).

Figure 6.2-5. Multiple Person / Multiple Transaction Checkboxes

If the Multiple Persons check box is selected, an Multiple Persons page will appear at the bottom of the screen allowing you to enter information pertaining to the additional person. Selecting Multiple Transactions will inform FinCEN that the CTR is related to multiple transactions.

Part II of the CTR provides six (6) fields for account numbers. If more than six (6) accounts are related to a specific CTR, additional account numbers may be reported by selecting the Add/Edit Additional Accounts button. This action will navigate you to Additional Account Numbers pages, where you can report up to six (6) more account numbers on each subsequent page. Note that the Add/Edit Additional Accounts button will not be active until all six (6) account fields are complete (see Figure 6.2-6).

Figure 6.2-6. Add/Edit Additional Accounts





When the form is ready for submission to FinCEN (all yellow fields are required and must be complete), Click the Validate button to show the remaining required and invalid fields (see Figure 6.2-7). Fill in the remaining fields correctly. Click the validate button again, you should only receive the error that the form is not signed with a PIN.

Figure 6.2-7. Validate Button

To digitally sign a form ready for submission to FinCEN using a PIN, click on the Sign with PIN button (see Figure 6.2-8) located on BSA Currency Transaction Report Header page of the CTR. Enter your assigned PIN and click on Sign with PIN in the Sign PIN window (see Figure 6.2-9).

Figure 6.2-8. Sign with PIN Button

Figure 6.2-9. Form Signed with PIN Button

Version 3.8 – July 2011



Note: Once a form is signed it cannot be modified without un-signing the form. Please see Step 12 for further instructions regarding un-signing forms.

10. Save the CTR Form: You can save CTR forms locally on your workstation or local area network at any point in the completion process and reopen them later when you wish to resume working. To save a form, click on the Save button in the top-left corner of the BSA E-Filing Currency Transaction Report Header page. In the Save a Copy or Save As window, enter the file name and click on Save (see Figure 6.2-11).

Note: You must use the Save button on the header page. If you use the Save option on the File menu, it will not prompt the Specify Filename Window.

Figure 6.2-10. Save Buttons

Note: The form is saved on your computer, not on BSA E-Filing. It is highly recommended that you retain a soft copy of the filing locally after submitting the filing, in the event that you must correct and resubmit the filing in response to an acknowledgement error received from FinCEN. In Section 10.0 Tips for Using BSA E-Filing – 10.1 Reducing Form Preparation Time, you will find instructions for how you can use the saved forms as templates to help optimize your use of the BSA electronic forms and related submission processes.


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Figure 6.2-11. Save Form Specify Filename Window

Figure 6.2-12. Validation Errors Window


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Note: If you attempt to save an incomplete and/or unsigned form, you will see a warning that one or more items (fields) within the form are not valid (see Figure 6.2-12). If desired, you may proceed by clicking OK to continue and save the incomplete form.

11. Open a saved CTR form: To open a CTR (completed or not) that you have saved locally (e.g., on your hard drive or network drive), click on File CTR from the BSA E-Filing Homepage. Next click on Browse on the Open a Form page. Then browse for the form to be opened in the Choose File pop-up window, and click on Open (Adobe Reader forms have the file extension ‘.pdf’). The file name will appear in the field to the left of the Browse button. Click on Open Existing Form to open the saved CTR form (see Figure 6.2-13).

Note: Once you have submitted filings to BSA E-Filing, you will not be able to retrieve them from BSA E-Filing. However, you will be able to retrieve any filings that you have stored locally on your computer or network.

Figure 6.2-13. Choose File Window


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Note: You can also open and edit CTR forms outside of BSA E-Filing. To view the form you must have the Adobe Reader Software on your computer. To open the form, browse for the form in your file directory (e.g. Windows Explorer) and double click on the file name of the form you wish to view.

12. Un-signing a Signed CTR Form: To un-sign a form to edit the contents of the filing, click on the Remove Signature button (see Figure 6.2-14) located on BSA E-Filing Currency Transaction Report Header page of the CTR. Click Yes to confirm. Please note that you may un-sign a form that has been signed by any user, but you can only re-sign it with your PIN. The un-signed form may now be edited.

Figure 6.2-14. Remove Signature Button

13. Printing a CTR Form: To print a CTR form, return to the BSA E-Filing Currency Transaction Report Header page and click on the Print button. If there are validation errors, the validation error window will popup. Click OK to continue. Another window will popup “There are validation errors. Are you sure you want to print the form?” Click Yes. A warning message will pop up, Warning: Printed versions of the BSA E-Filing forms are not for submission to the ECC-D and will not be processed at the ECC-D.” Click OK to continue. In the Print window, select your print options and click on OK (see figure 6.2-15).


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Figure 6.2-15. Print Window

14. Submit a signed and saved CTR form to BSA E-Filing: To submit a CTR form to BSA E-Filing, ensure that you have completed the form in accordance with the filing instructions, signed it and then saved it. From the BSA E-Filing Currency Transaction Report Header page, click on the Submit button (see Figure 6.2-16). Note: In the case that you attempt to submit an incomplete, unsigned or unsaved CTR, the Submit button will not function and will prevent you from submitting that CTR.

Figure 6.2-16. Submit Button


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Upon successful submission, a confirmation page (see Figure 6.2-17) will be presented, which will confirm:

Submission type•

Owner (submitter) Name•

Owner (submitter) e-mail address•

Receipt number (A unique tracking ID assigned to the filing by BSA E-Filing)•

Date and time of the submission•

Print this confirmation page for your records and save it as an HTML or PDF file. To print the confirmation page, press the ‘Ctrl + p’ keys simultaneously, or click your right mouse button and select Print, or select File from the top menu bar then select Print. To save the confirmation page, press the ‘Ctrl + s’ keys simultaneously, or right click on your mouse and select Save, or select File from the top menu bar then select Save. You will also receive an email confirming that your submission has been received. To close the confirmation page window, click the CLOSE button located immediately below the confirmation information or the ‘x’ box at the top right of the confirmation page window.

Note: Reports submitted with an Invalid PIN will receive a Submission Error page instead of a submission confirmation page. If you receive a Submission Error page due to an Invalid PIN, you must use the Browse button provided at the bottom of the page to locate your file in order to enter the correct PIN and resubmit using the original filing name. If you do not receive a submission confirmation page or a notification email, or you receive an error page, please check the status of your submission on the Track Status screen. Steps for this procedure are described later in Section 6.7, Track the Status of Filings. It may require up to ten minutes after submission for a filing’s information to appear on the Track Status screen. If you locate the filing name (i.e., the name you assigned to the filing) on the Track Status screen and the status is ‘Received’, wait for at least ten minutes and click on Track Status again. If the status is ‘Accepted,’ there is no further action required. If the submission is not listed or the status is listed as ‘Rejected’ or ‘Invalid PIN,’ you must resubmit the filing using the original filing name. For an Invalid PIN status, you must resubmit the filing using the original filing name with a valid PIN. A valid PIN can be generated by clicking on the Obtain New PIN link on the left navigation column. Please be aware that Invalid PIN submissions will no longer be displayed in the Track Status as of July 1, 2011.


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Figure 6.2-17. Confirmation Page Window


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6.3 Batch Filing of BSA Forms

The following example provides the basic steps for filling out, signing, and submitting batch filings of CTRs. Note that the process for filling out and submitting any batch BSA form is similar to this example. (However, for other BSA forms, the electronic filing requirements may be different from the requirements provided in this example. Please ensure that you have the correct requirements for your batch forms.)

This section describes how to submit an electronic batch of CTRs. Before proceeding, note the following items regarding batch filing of CTRs:

Batches must already be in the format specified by the • BSA Electronic Filing Requirements for the Currency Transaction Report (FinCEN Form 104) and Designation of Exempt Person (FinCEN Form 110). BSA E-Filing will NOT process batches of CTRs that are not in the format specified in this document.

Batches created by your mainframe system must maintain FinCEN’s specified • format following the download process to a BSA E-Filing accessible personal computer. Please consult the steps identified in section 6.4 Downloading Batch Files with BSA Electronic Filing Requirements for guidance.

Batches can be submitted in either ASCII or EBCDIC format. (The resulting • Acknowledgement files will be returned to you in the same format as the original filing. For example, if a batch file is submitted in ASCII format, then the resulting Acknowledgement file will be in ASCII format.) If a batch is submitted in EBCDIC format, the resulting Acknowledgement file will be in EBCDIC format.)

Batches can contain up to 99,999 CTRs/DEPs/CTRCs/SARs (discrete filings).•

The current limit on the size of batches submitted to BSA E-Filing is 60MB.•

BSA E-Filing will not accept compressed files. BSA E-Filing will automatically • compress files during the submission process. Decompress or unzip any compressed (or zipped) batch files before submitting them to BSA E-Filing.

Upon submission, the BSA E-Filing System will validate the batch data for • ‘format errors’ against the BSA Electronic Filing Requirements for the specific file type before it is sent to FinCEN. If ‘format errors’ are found, the submission will receive a ‘Rejected’ status. Such file format errors include but are not limited to Invalid Character, Invalid Line Length, Invalid Record Sequencing, and Invalid File Type.


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Currently CTR/DEP and CTRC batch files are ran through an additional batch file • validation to ensure the quality of data. If data errors are found, the submission will receive either “Accepted with Warnings’ or ‘Rejected’ status depending on the amount and severity of errors found. If the batch file receives ‘Accepted with Warnings,’ the file will be processed to FinCEN for acknowledgement. However, if the batch file is ‘Rejected,’ the file will not be processed to FinCEN.

If a CTR/DEP or CTRC batch file is rejected based on the severity of the errors • found, the user will have the opportunity to resubmit the same file by overriding the rejection. The user may also correct any errors with their software, and then resubmit the corrected file. For additional information on how to override a rejected file, please refer to section 6.9.4, Submitting CTR/DEP Batch Filings with Override Option.

SAR batch files will receive an acknowledgement file from FinCEN containing • assigned Document Control Numbers. The filing organization can elect to receive the acknowledgement file at their discretion by contacting the Supervisory User to initiate the enrollment (please refer to the Supervisory User Manual for further instruction).

Beginning in December 2009, SAR batch files will also be subjected to batch • validation to ensure data quality. SAR batch files will be validated against the SAR E-Filing Requirements. If data errors are found, the submission will receive ‘Accepted with Warnings’ and then processed to FinCEN for acknowledgement. Rejected SAR batch files will not have the override functionality as do CTR/DEP batch files.

6.4 Downloading Batch Files with BSA Electronic Filing Requirements

6.4.1 Requirements for ASCII CTR Batch Files:

Record length 220 data bytesd.

Preserve trailing spaces or pad each record to keep or make records a fixed e. size of 220 data bytes (when batch is being written, trailing spaces should be added to the end of the record data through the 220th character)

Only x’0D’ = 13 (CR – Carriage Return) and x’0A’ = 10 (LF – Line Feed) at the f. end of each line (trailing the 220 bytes)


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No control characters are permitted in the 220 data bytesg.

Must only be one blank line below the last record (if viewing the batch file, h. the cursor should rest in the first space of this blank line)

Data must be formatted according to requirements described in i. BSA Electronic Filing Requirements for the Currency Transaction Report (FinCEN Form 104) and Designation of Exempt Person (FinCEN Form 110)

6.4.2 Requirements for EBCDIC CTR Batch Files:

Record length 220 data bytesj.

Preserve trailing spaces or pad each record to keep or make records a fixed k. size of 220 data bytes (when batch is being written, trailing spaces should be ordered to the end of the record data through the 220th character)

No control characters at the end of each recordl.

Must be only one blank line below the last record (if viewing the batch file, m. the cursor should rest in the first space of this blank line).

Data must be formatted according to requirements described in n. BSA Electronic Filing Requirements for the Currency Transaction Report (FinCEN Form 104) and Designation of Exempt Person (FinCEN Form 110)

6.4.3 Considerations for Batch File Download from Mainframe

ASCII Filesa.

i. Using FTP client at Windows or Unix Server to connect to Mainframe (OS/390)

Set the data transfer type to binary on local ftp client (ftp> binary).1.

Set the transfer type to ASCII on Mainframe ftp (ftp> quote type 2. A). This will get the file in ASCII format. The only drawback to this approach is that the file loses the trailing spaces, which can be inserted using a post process.

Before the batch is submitted, make sure the file has the correct format 3. with fixed size records with trailing spaces as required and CR and LF at the end of each record.


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ii. Using a Specialized tool

If using specialized tools such as Connect:Direct, Network Data Mover, 4. NDM, or any Mainframe Terminal Emulation Software, the file transfer options must be configured in accordance with the characteristics described above in Sections ai1 and ai2.

b. EBCDIC Files

i. Using FTP client at Windows or Unix Server to connect to Mainframe (OS/390)

Set the data transfer type to binary on local ftp client (ftp> binary).1.

Set the transfer type to EBCDIC on Mainframe ftp (ftp> quote type 2. E). This will get the file in EBCDIC format. The only drawback to this approach is that the file loses the trailing spaces, which can be inserted using a post process.

Before the batch file is submitted make sure the file has the correct 3. format with fixed size records with trailing spaces and no control characters at the end of each record.

ii. Using Specialized tool

If you are using specialized tools like Connect:Direct (Network Data 1. Mover, NDM), then set the file transfer options according to the characteristics described in Sections ai1 and ai2.

c. Transferring batch files from download server (Windows or Unix) to Filer’s PC connected to BSA E-Filing

i. Using E-Mail

Do not add an extension to the batch file name.1.

Zip the file before attaching it to e-mail. Be sure to have the Filer unzip 2. the file before submitting it to BSA E-Filing.

ii. Using FTP

Use the ftp BINARY transfer mode from the local server to the user 1. workstation so that the files (whether ASCII or EBCDIC) keep their structure and format.


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6.5 Submitting a CTR/DEP Batch File on the BSA E-filing System of CTRs to BSA E-Filing, perform the following steps:

Select File Batch CTR/DEP:1. Click on File Batch CTR/DEP from the navigation menu on the left side of the BSA E-Filing System Homepage.

Select Open New Form:2. After clicking on File Batch CTR/DEP, the Open a Form page will appear (see Figure 6.5-1). From this page you may click on Open New Form to open a new BSA E-Filing CTR/DEP Batch Form. A new window with the BSA E-Filing CTR/DEP Batch Form is displayed (see Figure 6.5-2). You may also retrieve a previously created form that has been saved locally. That process is discussed in Step 1 in section 6.6; Open a saved BSA E-Filing CTR/DEP Batch Form.

Figure 6.5-1. Open Form Page Window


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Figure 6.5-2. BSA E-Filing CTR/DEP Batch Form Page


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3. Enter a Filing Name: On the BSA E-Filing CTR/DEP Batch Form, enter a unique name for the batch filing in the Filing Name field. This is a required field. This unique name will allow you to distinguish each batch filing. Please utilize naming conventions that will assist you in identifying the filing for tracking purposes. For example, you may consider using the date as part of the filing name (e.g. 05282002CTR1). See Section 10.4 for Filing Naming Conventions and Local Directory Storage.

Note: The Track Status table of BSA E-Filing will display the ‘Filing Name’ and status of each batch of CTR/DEPs you have submitted.

4. Indicate Batch File Format: Select either ASCII or EDCDIC from the Batch File Format drop-down box to indicate the file format of the batch that is being submitted.

5. Attach Batch file: Follow the steps below to add your CTR batch file as an attachment to the BSA E-Filing CTR/DEP Batch Form (the graphics that follow will help to illustrate this process).

5.1. Click on the Add Attachment button located in the middle of the BSA E-Filing CTR/DEP Batch Form (see Figure 6.5-3).

Figure 6.5-3. Add Attachment Button

5.2. In the ‘Select a data file to import’ window, browse for and select the desired batch file, and then click on Open (see Figure 6.5-4).


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Figure 6.5-4. Select a Data File to Import

5.3. You will now see an ‘x’ in the checkbox next to the Add Attachment button. Do not attach more than one batch file to a BSA E-Filing CTR/DEP Batch Form. If you attempt to do so, you will receive a warning message (see Figure 6.5-5).

Figure 6.5-5. Attachment Warning Window


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6. Indicate Number of Forms: Enter the total number of BSA documents in the Number of Forms field. The number should equal the total count of CTRs and/or DEPs that are included in the attached CTR/DEP batch file.

Note: The Track Status table BSA E-Filing will display the ‘Number of Documents’ (i.e. number of forms) for each batch of CTR/DEPs you have submitted

7. Enter Title: Enter your title in the Title field (see Figure 6.5-6).

Figure 6.5-6. Title Field

When the form is ready for submission to FinCEN, click the Validate button to show the remaining required and invalid fields. Fill in the remaining fields correctly. Click the Validate button again; you should only receive the error that the form is not signed with a PIN.

8. Digitally sign the BSA E-Filing CTR/DEP Batch Form: To digitally sign a form ready for submission to FinCEN using a PIN, click on the Sign with PIN button (see Figure 6.5-7). You must then enter your assigned PIN and click on Sign with PIN in the Sign with PIN window (see Figure 6.5-8).


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Figure 6.5-7. BSA E-Filing CTR/DEP Batch Form Page


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Figure 6.5-8. Sign with PIN Button

Note: Once a form is signed it cannot be modified without un-signing the form. Please see Section 6.2 Discrete Filing of BSA Forms for instructions regarding un-signing forms.

9. Save the Prepared Batch Form: To save the BSA E-Filing CTR/DEP Batch Form click on the Save button on the BSA E-Filing CTR/DEP Batch Form (see Figure 6.5-9). In the SAVE A COPY or SAVE AS window (shown below), enter the file name and click on Save.

Figure 6.5-9. Save Button

Note: The form is saved on your computer (not on BSA E-Filing). In Section 10.1 Reducing Form Preparation Time, you will find instructions for how you can use the saved forms as templates to help optimize your use of the Adobe Reader electronic forms and related submission processes.

10. Submit a Signed and Saved CTR/DEP batch: To submit a CTR/DEP Batch to BSA E-Filing, ensure that you have signed and saved the batch form (with the attachment). Click on the Submit button in the top-left corner of the BSA E-Filing CTR/DEP Batch Form (see Figure 6.5-10).


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Note: If you have not entered a filing name, attached a batch file, signed or saved the filing, then the Submit button will not function, preventing you from submitting the CTR Batch filing.

Figure 6.5-10. Submit Button

6.6 Opening a Saved BSA E-Filing CTR/DEP Batch Form and Unsigning a Form

Open a saved BSA E-Filing CTR/DEP Batch Form:1. To open a saved BSA E-Filing CTR/DEP Batch Form, click on File Batch CTR/DEP from the BSA E-Filing Homepage. Next, click on Browse on the Open a Form page. Then browse for the form to be opened in the Choose File pop-up window, and click on Open. The file name will appear in the field to the left of the Browse button. Click on Open Existing Form to open the saved BSA E-Filing CTR/DEP Batch Form (see Figure 6.6-1).

Note: Once you have submitted filings to BSA E-Filing, you will not be able to retrieve them from BSA E-Filing. However, you will be able to retrieve any filings you have saved locally on your computer or network.


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Figure 6.6-1. Choose File Window

Un-signing a Signed BSA E-Filing CTR/DEP Batch Form:2. To un-sign a form to edit the contents of the filing, click on the Remove Signature button (see Figure 6.6-2). Please note that you may un-sign a form that has been signed by any user, but you can only re-sign it with your PIN. The un-signed form may now be edited.

Figure 6.6-2. Remove Signature Button

Upon successful submission, a confirmation page (see Figure 6.6-3) will be presented which will confirm:

Tracking ID (a unique receipt number assigned to the file by BSA E-Filing)•

Receive Date/Time (the date and time that the file was submitted on BSA • E-Filing)

Submission type•


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Number of forms reported•

Owner (submitter) Name•

Owner (submitter) e-mail address•

Filing Name•

Figure 6.6-3. Confirmation Page Window

Print this confirmation page for your records and save it as an HTML or PDF file. To print the confirmation page, press the ‘Ctrl + p’ keys simultaneously, or click your right mouse button and select Print, or select File from the top menu bar then select Print. To save the confirmation page, either press the ‘Ctrl + s’ keys simultaneously, or right click on your mouse and select Save, or select File from the top menu bar then select Save. You will also receive an email confirming that your submission has been received. To close the confirmation page window click the CLOSE button located immediately below the confirmation information or close the browser by clicking the ‘X’ box at the top right of the confirmation window.


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Transmissions of large batch files with a file size of 30 megabytes or more may • require 10-20 minutes to transmit, and perhaps longer if you are using a slow Internet connection.

If you do not receive a submission confirmation page or notification email, or • you receive an error page, please check the status of your submission on the Track Status screen. Steps for this procedure are described later in Section 6.7 Tracking the Status of Filings. It may require up to ten minutes after submission for a filing’s information to appear on the Track Status screen, and longer for large files. If you locate the batch filing name (i.e., the name you assigned to the filing) on the Track Status screen and the status is ‘Received’, wait for at least one minute and click on Track Status again.

If the status is ‘Accepted’, there is no further action required. □

If the status is ‘Accepted with Warnings’, click on the ‘Accepted with □Warnings’ link to obtain a listing of the file errors to be corrected after the Acknowledgement is received from FinCEN.

If the submission is not listed or the status is listed as ‘Rejected’ or ‘Invalid □PIN,’ you must resubmit the filing using the original filing name.

For a ‘Rejected’ status, you must locate the ‘Rejected’ batch submission in □your Track Status and click on the ‘Rejected’ link to obtain a listing of the file errors to be corrected. See section 6.7 Track the Status of Filings for more information on ‘Rejected’ filings.

For an Invalid PIN status, you must resubmit the filing using the original □filing name with a valid PIN. A valid PIN can be generated by clicking on the Obtain New PIN link on the left navigation column. You can retrieve your new PIN from your secure message inbox on the BSA E-Filing System.


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6.7 Track the Status of Filings

You can use the Track Status feature to track your BSA E-Filing submissions. The Track Status feature allows you to determine where in the routing process to FinCEN a particular BSA filing is. Note that the Track Status screen shows tracking information at a batch level for batch filings and at an individual level for discrete filings.

To use the Track Status feature:

1. Select Track Status from the BSA E-Filing navigation menu. The filing history will appear along with the filings status for the past 365 days. Note: On July 1, 2011, the BSA E-Filing System will increase the filing history retention period to 1825 days (i.e. 5 years) in the Track Status screen.

2. You may filter/search Track Status information by selecting a specified date range from the Date Range drop down menu and/or entering a specific Tracking ID, DCN (Document Control Number), or Status (e.g. “Transmitted”) in the relative field. Once the filter/search criterion has been entered, click Search to display the results (see Figure 6.7-1).

Figure 6.7-1. Track Filter/Search Options


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The tracking statuses for the successful routing of all CTR type filings (CTR/DEP/CTR-C discrete, and batch) to FinCEN include:

‘• Received’ – Your filing has been received by BSA E-Filing but has not yet been validated.

‘• Accepted’ – BSA E-Filing has completed the validation process and has accepted your filing.

‘• Transmitted’ – Your filing has been transmitted by BSA E-Filing to FinCEN.

‘• Acknowledged’ – FinCEN has sent an acknowledgement to BSA E-Filing and BSA E-Filing has sent that acknowledgement to you.

The tracking statuses for the successful routing of SAR type filings (discrete) include:

‘Received’• – Your filing has been received by BSA E-Filing but has not yet been validated.



‘• Acknowledged’ – FinCEN has sent an acknowledgement to BSA E-Filing and BSA E-Filing has sent that acknowledgement to you.

The tracking statuses for the successful routing of SAR type filings (batch) include:

‘• Received’ – Your filing has been received by BSA E-Filing but has not yet been validated.



‘• Acknowledged*’ – FinCEN has sent an acknowledgement to BSA E-Filing and BSA E-Filing has sent that acknowledgement to you.

(*Acknowledgements are only available to SAR batch filers if the filing organization is enrolled to receive SAR batch acknowledgements. Please refer to the Supervisory User Manual for instructions to enroll.)


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The tracking statuses that indicate errors for filings are as follows:

‘• Accepted with Warnings’ – This submission has been Accepted and will be processed by FinCEN. However it contains some errors which need to be corrected once this submission has been acknowledged. Filer reviews the warnings on the Submission Warnings page by clicking the Accepted with Warnings link on Track Status for the submission. The filer can also optionally download the warnings by clicking on the Download as XML button on this page to receive full detail of the warnings.

Note: The Submission Warnings screen displays important details concerning the types of errors received and the location within the submitted file associated with the error. Filers should refer to the column titled ‘Context’ for the location within the submitted file where the error was generated. This field will often list the record type, field description, line number, and document number3 (if applicable).

Figure 6.7-2. Submission Warnings Page

The document number is equal to the transaction sequence number for each document within the 3. batch submission. The first document within the batch will have transaction sequence number ‘00001’ and will increment by one for each additional document. For more information regarding the transaction sequence number, please refer to the BSA E-Filing Electronic Filing Requirements by form type at http://www.fincen.gov.


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Figure 6.7-3. Download as XML Page

Note: The Download as XML button allows the user to optionally download the Batch Validation warnings or errors shown on the Submission Warnings or Submission Errors page as XML data. This XML data is optional and is not required in order to view or fix the batch validation errors/warnings. However, a user can utilize this XML file to process the batch validation errors in a machine readable manner, and allows for automation of the error/warning review and correction process. The XML schema for this XML data can be downloaded from the following URLS (you must be logged in to BSA E-Filing to access the URL):

For CTR/DEP batch files: https://bsaefiling1.fincen.treas.gov/forms/BSAEFilingBatchMessages.xsd.

<?xml version=”1.0” encoding=”UTF-8”?><BatchMessages xmlns:xsi=”http://www.w3.org/2001/XMLSchema-instance”xsi:noNamespaceSchemaLocation=”BSAEFilingBatchMessages.xsd”> <Batch trackingID=”CB08-00000025” type=”CTR” filingName=”CTR” status=”REJECTED” filingDate=”2008-01-22”> <Message code=”111” level=”ERROR”> <Context lineNumber=”127”>5A:OrgOrIndivName [Line: 127]</Context> <Description>Owner Name is invalid. a. Blank, b. not in proper format, c. contains no slashes for individual.</Description> </Message> <Message code=”022” level=”ERROR”> <Context lineNumber=”201”>3A:TransAmtCashout [Line: 201]</Context> <Description>Cash In or Cash out is missing or non-numeric.</Description> </Message> <Message code=”E01” level=”ERROR”> <Context/> <Description>Cannot continue processing the submitted file because of previous errors encountered. Please fix and re-submit file or re-submit file with override applied.</Description> </Message> </Batch></BatchMessages>


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The XML schema for each SAR form type is available at:

https://bsaefiling1.fincen.treas.gov/ackSchemas/SARAcknowledgementData.xsd

https://bsaefiling1.fincen.treas.gov/ackSchemas/SARCAcknowledgementData.xsd

https://bsaefiling1.fincen.treas.gov/ackSchemas/SARSFAcknowledgementData.xsd

https://bsaefiling1.fincen.treas.gov/ackSchemas/SARMSBAcknowledgementData.xsd

https://bsaefiling1.fincen.treas.gov/ackSchemas/CommonAcknowledgementDataTypes.xsd

‘Transmitted with Warnings’• - When a submission that was previously Accepted with Warnings is transmitted to FinCEN, the status becomes Transmitted with Warnings. The user can click on the Transmitted with Warnings link to view warnings that were issued for the submission; however, the institution must wait until they receive the Acknowledgement file from FinCEN in order to correct and resubmit their batch submission. The institution must wait for the Acknowledgement file because a Document Control Number (DCN) is required for corrected submissions and the DCN is in the Acknowledgement file.

‘Rejected’• – This status can apply to both types of submissions: discrete and batch.

Both types of submissions (discrete and batch) will receive a status of ‘Rejected’ when an invalid form version is used or the role has NOT been assigned to the user. Contact your Supervisory User to verify your current roles, in the latter case, your submission will need to be corrected and resubmitted. For additional assistance, contact the BSA E-Filing Help Desk.

Batch submissions will also receive a ‘Rejected’ status if the batch fails to meet the BSA Electronic Filing Requirements upon submission to the BSA E-Filing system. Click on the ‘Rejected’ link in your Track Status to obtain a listing of the file errors to be corrected. Refer to the BSA Electronic Filing Requirements specifications for a detailed list of file errors. Users have the option of correcting the identified errors in a batch file due to data and/or format issues before resubmitting the file OR users can resubmit the same batch file (without correcting the identified errors) with the override option applied if the batch file has no FATAL errors. If the batch file has one or more FATAL errors, then the file must be corrected and the override option cannot be applied. Instructions on submitting a batch file with the override option applied are provided in section 6.9.4 Submitting CTR/DEP Batch Filings with Override Option.


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Figure 6.7-4. Submission Errors Window

Acknowledge Error• – This status only applies to discrete filings. It indicates that an acknowledgement has been created and routed to the user to inform the user of errors found in the filing. Click on the ‘Acknowledge Error’ link in your Track Status to obtain a listing of the errors to be corrected. Each acknowledgement contains a Document Control Number (DCN).


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Figure 6.7-5. Acknowledge Error Codes Window

Correct any filing with this status and resubmit it with the DCN provided by FinCEN. Instructions for submitting corrections are provided in Section 6.8.5

‘• Acknowledge Failed’ – Applies to batch filings only. FinCEN was unable to load the batch filing. Therefore, an acknowledgement file could not be generated. Contact the BSA E-Filing Help Desk if this error message appears if you are unable to determine the problem with the format of the batch file.

‘Invalid PIN’• – The PIN on the submitted filing does not match the PIN stored in the system database. Remove the invalid PIN from the submission and resign it with the correct PIN. The PIN on the submission must be the PIN assigned to the person logged into BSA when the submit button is clicked. A user cannot submit a submission signed using someone else’s PIN.

‘Hold’ • – The filing was placed on Hold by the system administrator. Contact the BSA E-Filing Help Desk.

The tracking statuses for the successful routing of discrete SAR type filings (SAR-DI, SAR-C, SAR-MSB, SAR-SF) to FinCEN include ‘Received,’ ‘Accepted,’ ‘Transmitted’, Acknowledged,’ and ‘Hold.’


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The tracking statuses for the successful routing of SAR batch filings to FinCEN include ‘Received,’ ‘Accepted,’ ‘Transmitted,’ ‘Acknowledged’ (if your filing organization enrolled to receive SAR batch acknowledgements), and ‘Hold.’

Note: Unless you are a Supervisory User for your filing organization, you will only be able to track the filings you have personally submitted. Supervisory Users are able to track all the filings submitted by all of their organization’s filers. Supervisory Users cannot see the content of submissions. They can only see the status of submissions. Only Supervisory Users can initiate and manage the enrollment of SAR batch acknowledgements.

6.8 Acknowledgements

Each BSA E-Filing Form, CTR, CTR-C, DEP, and SAR type filing (either discrete or batch) submitted through BSA E-Filing will receive a corresponding positive or negative acknowledgement from FinCEN. For SAR batch filings upon enrollment by the filing organization’s supervisory user, each SAR type of filing of batch forms will receive a corresponding positive or negative acknowledgement. These acknowledgements of filings received by FinCEN will be made available to users on the BSA E-Filing site. Acknowledgements are routed to users via Secure Messages. Users receive an email notification from BSA E-Filing informing them that a Secure Message is available for review, and provides the user with the BSA E-Filing URL address link. Users then navigate to BSA E-Filing and review their Secure Messages Inbox (View Inbox) to locate the acknowledgement.

6.8.1 Acknowledgement Email Notification

When BSA E-Filing receives acknowledgements from FinCEN for your filings, BSA E-Filing will send an email to you. The email will contain a link to BSA E-Filing as well as the Secure Message ID that contains the acknowledgement. The email will not contain any information about the acknowledgement’s content. Since you can only view acknowledgement content during a secure session on BSA E-Filing, you will need your user ID and password to authenticate your access into BSA E-Filing after clicking on the BSA E-Filing link. Once you’re in BSA E-Filing, you will be able to access the content of the acknowledgement.

It is important to realize that email is not a guaranteed delivery system. Although most individuals and organizations have email and use it for important


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correspondence, it was not designed nor implemented as a communications system with guaranteed delivery to the intended recipient without alteration/corruption. Therefore, there may be instances where due to errors in the Internet system, email messages are delayed, corrupted, delivered to unintended recipients, delivered multiple times, or not delivered.

Submission status should be tracked regularly. Select the Track Status link under the Filing heading on the left navigation menu which provides a list of an individual’s filings and filing status. The Track Status feature allows you to determine where in the routing process to FinCEN a particular BSA filing is. Note that the Track Status screen shows tracking information at a batch level for batches that have been submitted and at an individual level for discrete filings.

If you do not receive acknowledgements in Track Status within 3 days of a submission requiring acknowledgements, you should contact the BSA E-Filing Help Desk.

BSA E-Filing Users are strongly encouraged to keep BSA E-Filing apprised of their current email address and use the Track Status and Secure Message functions of BSA E-Filing daily to track the progress of submissions.


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6.8.2 Accessing Acknowledgements

Access BSA E-Filing by either clicking on the BSA E-Filing URL contained in the 1. acknowledgement notification email sent to you or by navigating to the BSA E-Filing site by entering the BSA E-Filing URL address into your Internet browser window.

Provide your user ID and password to gain access to BSA E-Filing.2.

Select 3. View Inbox from the BSA E-Filing navigation menu to view your Secure Messages.

Identify the new Secure Message using the Secure Message ID (RM#) provided in 4. the email notification.

Figure 6.8-1. View Inbox Screen

5. Click on the Subject of the Secure Message that contains your Acknowledgement. The Secure Message subject field will include the filing tracking ID assigned to the filing upon submission in order for you to reconcile



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the acknowledgement with the filings you have submitted. The text box of the Secure Message will contain the Acknowledgement content for the discrete filing, as shown in the following graphic.

Figure 6.8-2. Secure Message Reply Form Window


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A batch filing acknowledgement will arrive as an attachment to a Secure Message as shown in the following graphic.

Figure 6.8-3. Secure Message Reply Form


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6.8.3 Storing Acknowledgements for Your Records

BSA E-Filing retains information for a limited time. Refer to Section 6.10 BSA E-Filing Administrative Data Retention Policy for data retention details. For this reason and in order to show your BSA regulator proof that a filing was received by FinCEN, download and store acknowledgements for your permanent records. You can save discrete filing acknowledgements as a PDF file. Save the separate attachments of your batch filing acknowledgements.

To save a discrete acknowledgement, click on the • Save button located in the Secure Message containing the acknowledgement. You can view these PDF files subsequently with your Adobe Reader software. The Adobe Reader will automatically launch when you attempt to open a PDF file.

To save a batch acknowledgement, click on the • View/Save Attachment Button within the Secure Message containing the acknowledgment; click View/Save and browse to the location to save the file. Once you have stored your batch acknowledgement locally, you may upload the acknowledgement to your mainframe system. Below are the steps to follow to ensure that the BSA E-Filing Electronic Filing Requirements specified format is maintained throughout the uploading of the acknowledgement to your mainframe.

6.8.4 Considerations for Acknowledgment File Upload to Mainframe

ASCII Filese.

Using FTP client on Windows or Unix Server to connect to Mainframe

Set the data transfer type to binary on local ftp client. 1.

Set the transfer type to ASCII on Mainframe ftp (ftp> quote type A). 2. This will upload the acknowledgment file in ASCII format with proper (CR/LF) line termination characters.

Set Record Format to Fixed Block, appropriate Logical Record Length 3. (57 for acknowledgement file), appropriate block size using SITE command (e.g., SITE RECFM=FB LRECL=57 BLKSIZE=????)


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ii. Using Specialized Tool

If you are using the specialized tools like Connect:Direct (Network 1. Data Movers (NDM)) or any Mainframe Terminal Emulation Software, then set the file transfer options according to the characteristics described in paragraph a.i Steps 1 and 2.

b. EBCDIC Files

i. Using FTP client at Windows or Unix Server to connect to Mainframe

Set the data transfer type to binary on local ftp client. 1.

Set the transfer type to EBCDIC on Mainframe ftp (ftp> quote type E). 2. This will upload the acknowledgment file in EBCDIC format with no line termination characters.

Set the Record Format to Fixed Block, appropriate Logical Record 3. Length (57 for acknowledgement file), appropriate block size using SITE. command (SITE RECFM=FB LRECL=57 BLKSIZE=????)

ii. Using Specialized Tool

If you are using the specialized tools like Connect:Direct (Network 1. Data Movers (NDM)) or any Mainframe Terminal Emulation Software, then set the file transfer options according to paragraph b.i Steps 1 and

6.8.5 Taking Corrective Action in Response to Negative Acknowledgements for CTR, CTR-C or DEP Filings

Correct all filings for which you receive negative acknowledgements and re-submit them to BSA E-Filing. DO NOT respond to acknowledgement errors by replying to the secure message reply which contained the acknowledgement.

Discrete CTR Type of Filing 1.

i. Review acknowledgement information to determine what additional information is required and/or what information must be corrected.

ii. Recall original document in locally stored archives.

iii. Un-sign the form by clicking on the Remove Signature button; click Yes.

iv. Make required edits to the form.


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v. Change Submission type from ‘New’ to Amendment’ and place Document Control Number (DCN) in the DCN Field.

vi. Sign the form by clicking on the Sign with PIN button and save the form by clicking on the Save button.

vii. Resubmit form by clicking Submit button.

2. Batch CTR Type of Filings

i. Run batch acknowledgement file received from FinCEN in your mainframe to read the acknowledgement details.

ii. Edit appropriate filings as directed by acknowledgement.

iii. Resubmit batch with corrected information.

Special Note – Acknowledgement errors related to SSNs (social security numbers) or EINs (employer identification numbers):

FinCEN will send acknowledgement errors to CTR type filers when FinCEN records indicate a possible mismatch between a SSN or EIN for a transactor or owner identified in a filing. Error codes 104, 105, 128, and 129 are an indication of these particular acknowledgement errors. These specific types of acknowledgements are warnings only and will be accompanied by the following text:

“The following error reflects a possible mismatch between the name reported and the corresponding SSN/EIN. We would greatly appreciate any assistance you can provide to verify that the name and number are correct.”

If you receive such a warning, FinCEN asks that you check your records to verify that the SSNs and EINs you provided on the filing match the numbers in your records. If the numbers provided in the filing do match the numbers contained in your records, no further action on your part is required. However, if you find that the numbers do not match, FinCEN requests that a corrected CTR be filed with the correct SSN/EIN numbers. Please follow the steps in Section 6.8 for correcting a CTR type of filing.


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6.9 Amending or Correcting Previously Submitted Filings

If you have an occasion to amend or correct a previously submitted filing, please follow the instructions below. Instructions are provided for discrete CTR and SAR filings, the type of CTR or SAR is not relevant as the instructions below apply to all types of CTR, SAR and DEP BSA forms. CTR files can only be “New” or “Amendments.” DEP files can only be “New” or “Correction/Replacement.” In the case of a SAR, you would initiate a correction after discovering incorrect information on a previously submitted filing.

6.9.1 Submitting an Amended Discrete Type of CTR

Wait until an acknowledgement is received for the original filing.1.

Obtain the Document Control Number (DCN) from the acknowledgement.2.

Locate the saved copy of the original filing from your organization’s electronic 3. records. See Section 6.2 of this manual for more details about opening a saved CTR form.

Note: If an electronic copy has not been retained, the filing will have to be completed from scratch. You should reference a printed version of the filing so that you can transcribe information from the original filing into a new form and edit it appropriately.

Open the file through the website by clicking on File CTR, Select 1. browse, locate the original form, and then click Open Existing Form..

Un-sign the CTR form. For details, see in Section 6.2, step 12 of this manual.2.

On the 3. BSA E-Filing Currency Transaction Report Header page, select Amendment in the ‘Submission Type’ field. If you select Amendment, the system will automatically check box 1a ‘Amends prior reports ‘ on the form.

Enter the DCN provided in the acknowledgement received for the original filing 4. into the DCN field.

Add or edit CTR information as applicable.5.

This is a significant difference from the paper filing process where an amendment or correction only requires that the affected fields be completed.


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Validate the CTR form. For details, see Section 6.2 of this manual.6.

Digitally sign the CTR form. For details, see Section 6.2 of this manual.7.

Save the CTR form using 8. SAVE AS on the file menu in order to rename the file.

Note: Use a different filing name from the name of the filing that is being amended. You might consider just adding to the original filing name. For example, use ‘XYZ Filing (Amendment)’.

9. Submit the amended filing by clicking on the Submit button located on the top left corner of the BSA Currency Transaction Report Header page.

6.9.2 Submitting a Corrected Discrete SAR Type Filing

Locate the saved copy of the original filing from your organization’s electronic 1. records.

Note: If an electronic copy has not been saved, the filing will have to be completed from scratch. You should reference a printed version of the filing so you can transcribe information from the original filing into a new form and edit it appropriately.

Open the file through the website by clicking on File SAR, Select 2. browse, locate original form, and then click Open Existing form.

Un-sign the SAR form. For details, see Section 6.2 of this manual,3.

Check the box at the top of the report (line 1), labeled ‘Corrects Prior Report’. 4.

Correct the SAR and describe the changes that are being made, and include the 5. Document Control Number (DCN) assigned to the original SAR filing in Part V, (Suspicious Activity Information Explanation/Description).

Digitally sign the SAR form. For details, see Section 6.2 of this manual.6.

Save the SAR form using 7. SAVE AS on the File Menu in order to rename the file. For details, see Section 6.2 of this manual.

Note: Use a different filing name from the name of the filing that is being corrected. You might consider just adding to the original filing name. For example use XYZ Filing (Correction).

Submit the corrected filing by clicking on the 8. Submit button located on the top left corner of the BSA E-Filing Suspicious Activity Report Header page.


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6.9.3 Submitting CTR/DEP or SAR Batch Amendments or Corrections

The process for submitting amendments or corrections to a filing contained in a batch file is based upon your Organization’s process. However, the actual resubmission of the batch is the same process as previously described in Section 6.3 to submit a batch of CTRs to BSA E-Filing.

6.9.4 Submitting CTR/DEP Batch Filings with Override Option

When a batch file is ‘Rejected’, filers have the option to override the rejected status. The filer will pull up a new BSA E-Filing CTR/DEP Batch Form and click on the Overrides Rejected Submission checkbox (see Figure 6.9.4-1).


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Figure 6.9.4-1. BSA E-Filing CTR/DEP Batch form with Override Rejected


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The filer completes the batch form with the override option checked, enters the original submission Tracking ID and the reason for the override, signs, saves and submits form.

Figure 6.9.4-2. Batch form with override (filled out)


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Filer will receive a confirmation screen with a new Tracking ID and an e-mail that the submission is Accepted with Warnings. Filer will go to Track Status to confirm status is Accepted with Warnings. Filer will click on Accepted with Warnings link to review the filing’s Submission Error details.

6.10 BSA E-Filing Administrative Data Retention Policy

BSA E-Filing retains administrative data as follows:

Administrative Data Type Retention TimeAcknowledgement Data 30 days after being opened or 60 days after

beingposted,whichevercomesfirstAlert Data 30 days after postingTrack Status Data 365 days after achieving ‘Accepted’ or

‘Rejected’status.Note:Theretentionperiodwill be increased to 1825 days (i.e. 5 years) as of July 1, 2011.

Figure 6.10-1. Administrative Data Retention Policy Table

Note: It is recommended that you perform electronic and/or hardcopy archival of administrative data to support your organization’s archival requirements since BSA E-Filing does not retain it past the time periods described above.


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7. Alerts

FinCEN will use the BSA E-Filing Alerts feature to distribute FinCEN advisories and system updates.

Note: Only specific individuals within each filing organization will have access to Alerts and the Secure Messaging functions, as determined by their Supervisory Users.

7.1 Accessing Alerts

Alert email notification:1. Any time FinCEN posts an Alert on BSA E-Filing, you will also receive an Alert email notification at your email address. The email will contain a link to BSA E-Filing. The email will not contain any information about the Alert’s content. Since you can only view Alert content during a secure session on BSA E-Filing, you will need your user ID and password to authenticate your access into BSA E-Filing after clicking on the BSA E-Filing link.

Accessing an Alert: 2. You can access Alerts during a BSA E-Filing online session by selecting View Alerts from the BSA E-Filing left navigation menu. This action will present BSA E-Filing Alerts within the main content window, as shown below. You will only be able to view alerts posted since the time you gained rights to BSA E-Filing Alerts (at the point of enrollment, if you are a Supervisory User, or when your Supervisory User granted Alerts privileges to you).


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Figure 7.1-1. View Alerts Screen

To view an individual Alert, simply click on the ‘Subject’ of the Alert to be • viewed. You will see the Alert content in a separate Adobe Reader form window as shown in the following graphic. Note that the Alert may also have attachments that you can download.


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Figure 7.1-2. Alert Form Window


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Figure 7.1-3. View/Save Attachment Button

To view or save a file attached to an Alert (if the attachments check box is • checked), click on View/Save Attachment. If there is more than one attachment, click on the attachment you wish to view or save, and then click on View/Save. You will then be prompted to specify a file to extract to. Choose the folder location and file name and click Save. The open File window will appear. Specify how you want to open the file and click OK.

Figure 7.1-4. Attachments Window


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Figure 7.1-5. File Download Box


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8. Secure Messaging

Secure Messaging allows filing organizations to communicate directly to FinCEN. For example, a filing organization might use Secure Messaging if it wishes to communicate sensitive information to FinCEN that it cannot send to the ECC-D in a BSA E-Filing filing. FinCEN uses the Secure Messaging Replies to respond to Secure Messages submitted by filing organizations. Secure Messaging Replies can also route acknowledgements to you, as discussed in Section 6.8 of this manual. Respond to acknowledgement errors according to the instructions contained in Section 6.9 Amending or Correcting Previously Submitted Filings. Do not use Secure Messaging to reply to acknowledgements. In your Secure Message, please include contact information such as telephone number and e-mail address in case there is a need for additional information from you.

The Secure Messaging function is only available if your Supervisory User has granted you access to the Secure Messaging function.

8.1 Creating and Sending a Secure Message

To send a Secure Message to FinCEN select Send Message from the BSA E-Filing left navigation menu. This action will present a blank Secure Message form in a separate window, as shown in the following graphic.

For questions related to operating the BSA E-Filing site, please contact the BSA E-Filing Help Desk at BSA E-Filing Help Desk at 1-866-346-9478 (option 1) or [email protected]. Please do not use Secure Messaging on BSA E-Filing to request BSA E-Filing operational assistance.


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Figure 8.1-1. Secure Message Form Window


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Your Secure Message may contain a text message as well as attached files. Enter a subject heading for the message in Subject field. Enter desired text in the text body of the message. To attach a file, simply click on Add Attachment, then select a file to import, then window will appear, and browse for the desired file. (Note: Compressed files will not be accepted as attachments to Secure Messages.) Save the message locally before submitting. Click on the Save button. (Note: The form is saved on your computer, not on BSA E-Filing.) To send the message, first save it locally and then click on Submit.

Figure 8.1-2. Select a data file to import


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8.2 Viewing All Sent Messages

You may view previously sent Secure Messages while logged on to BSA E-Filing by selecting View Outbox from the BSA E-Filing left navigation menu. This action will present a list of all the sent Secure Messages within the main content window, as shown in the following graphic.

Figure 8.2-1. View Outbox Screen

To access the content of a Secure Message, simply click on the subject of the Secure Message. The Secure Message content will appear in a separate Adobe Reader form window. Filter Outbox messages by selecting a specified date range from the drop down menu or you can show all.

Figure 8.2-1. View Outbox Screen


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8.3 Receiving a Secure Message Reply

You will receive a Secure Message Reply email at the email address you provided during enrollment. The email will contain a link to the BSA E-Filing homepage. The email will not contain any information about the Secure Message Reply content. Since you can only view Secure Message Reply content during a secure session on BSA E-Filing, you will need your user ID and password to authenticate your access into BSA E-Filing after clicking on the BSA E-Filing link.

8.4 Accessing a Secure Message Reply

You can access a Secure Message Reply during a BSA E-Filing online session by selecting View Inbox from the BSA E-Filing left navigation menu. This action will present all the current Secure Message replies (which also contain acknowledgements) within the main content window, as shown in the following graphic.

Filter Secure message replies by selecting a specified date range from the drop down menu and secure messages from the specified date range will display in the View Inbox or you can show all.




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To access the content of a Secure Message Reply, simply click on the subject of the Secure Message. The Secure Message Reply content will appear in a separate Adobe Reader form window as shown in the following graphic.

To delete a Secure Message Reply, check the box next to the reply you wish to delete, and then click the Delete button.

You can mark all messages for deletion by clicking on Check All. You can deselect all messages by clicking on Clear All.

To access any files attached to the Secure Message Reply, click on View/Save Attachment, select the file (if more than one is attached), and then select View/Save when prompted. Specify a file to extract to. Choose the folder location and file name and click Save. The Open File window will appear. Specify how you want to open the file and click OK

Figure 8.4-2. Secure Message Reply Form Window


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Figure 8.4-3 View/Save Attachment

Figure 8.4-4 Attachment Window


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Figure 8.4-5 File Download Box

Figure 8.4-6 Open File Window


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9. Getting Help for BSA E-Filing

This manual is but one source of instruction and support for BSA E-Filing Users. Additional support materials are available for other purposes and other areas of the BSA E-Filing System. Additionally, live support is available if all available documentation fails to answer your questions.

9.1 BSA E-Filing System User Manual

As stated earlier in the document, this manual is designed to provide you with all the necessary information for using BSA E-Filing. This manual contains both procedural and technical information; therefore, you should expect to find detailed descriptions of the steps required to handle BSA E-Filing functionality such as BSA filings, receiving Alerts, and Secure Messaging communication with FinCEN, as well as the technical aspects of those steps that relate to you and your organization. As refinements are made to BSA E-Filing, subsequent updated versions of this manual will reflect the refinements. Contact the BSA E-Filing Help Desk for information that you cannot find within this manual or in the other training materials available on the site. Please see below for details about how to contact the BSA E-Filing Help Desk.

9.2 Supervisory User Manual

The BSA E-Filing Supervisory User Manual is a comprehensive guide to all the BSA E-Filing functionality that is specific to Supervisory Users, including initiating user enrollment, managing user access, maintaining filing organization information, and tracking the status of all filings from the organization. The Supervisory User Manual contains procedural and technical information on all aspects of BSA E-Filing that require Supervisory User status, but Supervisory Users will still need to refer to the User Manual for instructions on all standard BSA E-Filing functionality. The BSA E-Filing Supervisory User Manual is accessible from the BSA E-Filing secure site. Click on the Supervisory User Manual link located on the left navigation menu.

9.3 Computer-Based Training Module

The Computer-Based Training (CBT) module provides similar information as this manual, as well as the BSA E-Filing Supervisory User Manual. The CBT is a good supplement to the User and Supervisory User Manuals as it provides a high-level graphical overview of how users will interact with BSA E-Filing. The CBT


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is accessible from the BSA E-Filing secure site, by clicking on the Computer Based Training link located on the left navigation menu.

9.4 Quick Reference Guide

The BSA E-Filing Quick Reference Guide is an abbreviated BSA E-Filing users’ guide that highlights the main functions of BSA E-Filing. The Quick Reference Guide is accessible from the BSA E-Filing secure site by clicking on the Quick Reference link located on the left navigation menu.

9.5 Frequently Asked Questions

The Frequently Asked Questions identifies many of the more commonly asked questions about BSA E-Filing, how to operate the application, and what to do when facing a specific operational challenge. Answers to the frequently asked questions will provide all the information necessary to address the question, refer you to a specific portion of a BSA E-Filing user document that will provide the necessary details to answer the question, or refer you to the BSA E-Filing Help Desk for assistance. Frequently Asked Questions is accessible from the BSA E-Filing secure site, by clicking on the Frequently Asked Questions link located on the left navigation menu.

9.6 Contacting the BSA E-Filing Help Desk

Contact the BSA E-Filing Help Desk for technical or instructional support by calling 1-866-346-9478 (Option 1). Identify yourself as a BSA E-Filing user and the Help Desk will be able to assist you with issues involving technical difficulties or errors or instructional questions. This toll-free line will be accessible 24 hours per day, 7 days per week to accept your calls. BSA E-Filing Help Desk Technicians will respond to calls Monday through Friday between 8 AM EST and 6 PM EST. The BSA E-Filing Help Desk is also accessible via email at [email protected].

Please be advised that the BSA E-Filing Help Desk is not authorized by FinCEN to view any BSA filing data, so please do not disclose any details about the actual content contained in your BSA filings to the BSA E-Filing Help Desk.

Please direct all BSA regulatory questions to the FinCEN Regulatory Help-Line at 800-949-2732. All BSA E-Filing operational questions should be directed to the BSA E-Filing Help Desk.

Note: The Help Desk is CLOSED on Federal holidays.


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10. Tips for Using BSA E-Filing

Just as filing organizations vary in the methods they use to submit BSA filings, the internal processes and level of automation used to prepare and submit BSA filings also vary among filing organizations. This section presents a high-level overview of how a hypothetical bank could use BSA E-Filing to file BSA forms. The diagram on the next page shows how a hypothetical bank processes BSA forms.

Main Street Bank has three branches, named Branch 1, 2 and 3. Each branch processes CTRs and SARs in different ways. Branch 1 fills out CTR and SAR forms on paper at the teller level. Branch 2 uses the BSA E-Filing Adobe Reader software to fill out CTRs and SARs. Branch 3 uses their own internal system for capturing CTR information; the internal system is part of the Branch’s customer account and transaction system. Branch 3, however, fills out SARs on paper. All of Main Street’s branches forward their CTR information to a Compliance Department for review and submittal to BSA E-Filing.

Using the BSA Adobe Reader at the Branch Level: As you can see from the diagram, Branch 2 uses the BSA E-Filing Adobe Reader software to avoid the paper entry that Branch 1 goes through every day. Branch 2 staff has created branch-specific CTR templates with branch information pre-populated. In this scenario, no one at Branch 2 requires user IDs or even access to the BSA E-Filing website. The branch level staff (and the Compliance review staff) only requires the Adobe Reader software and the BSA E-Filing Adobe Reader CTR and SAR forms to complete and route CTR and SAR forms to other departments. Only the Compliance Officer who is signing, and the submitter who is physically submitting the forms, require a user ID and access to the BSA E-Filing website.


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Figure 10-1. Legend for Main Street Bank

Replacing Paper at the Branch Level: Branch 1 could gain efficiencies in their BSA processing by deploying the BSA E-Filing Adobe Reader CTR and SAR forms down to the teller level. In this way, tellers could fill out the forms and route them to the Compliance Department for review, digital signing, and submittal to BSA E-Filing.

Use of Internal Systems that Output FinCEN and BSA E-Filing Compliant Data: Branch 3 uses an internal CTR system that is part of their overall customer account and transaction processing system(s). Their system automatically routes CTR data to the Compliance Department, where staff can review the CTRs online and approve them for submission. Once approved, the internal system outputs all CTRs to a batch file that is already in the format required by FinCEN and BSA E-Filing. The batch file is submitted to BSA E-Filing once every 15 days, and acknowledgements are routed back to the submitter. This is a good process that works well and doesn’t need to be changed. There is not a requirement on the frequency of batch submissions.


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Figure 10-2. BSA E-Filing Forms Process


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10.1 Reducing Form Preparation Time

Organizations that file discrete BSA forms can use pre-populated BSA E-Filing Forms Viewer forms to reduce the amount of data that must be keyed-in for each form.

Pre-population of forms with information that will be common across all forms (i.e., filing organization name and location information as shown below), is a practice that you can apply to BSA forms, for both the cover information form and the BSA form itself. A partially pre-populated and saved form, as shown in the example below, will then act as a template for preparing filings.

Figure 10.1-1. Pre-populated Form Template


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You can create further customized templates for customers for whom you must frequently prepare filings. For example, you could pre-populate forms with customer information such as the name of the person conducting the transaction, Doing Business As (DBA) Name, SSN or EIN, address, and phone number. These customized forms would be specific to each customer as shown in the example below.

Figure 10.1-2. Pre-populated Form Template

Reducing the amount of data that must be entered for each filing through form pre-population will reduce the amount of time required to prepare BSA filings, and may also reduce the number of data entry errors. To create and access such pre-populated forms, please see the Save Completed Form and Open Saved Forms procedures for discrete and batch filings in Sections 6.2 and 6.3 of this manual.


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It is required that you save BSA form templates as Read Only files. This will prevent other filers within your organization that may share these templates from inadvertently saving a template after populating it with specific filing information. To save a template as Read Only, first save the file as discussed in Section 6.2 of this manual. Next go to your Windows Explorer and locate the file you wish to establish as Read Only. Right-click on the file name and click on Properties. A Properties pop-up window will appear. At the bottom of the General tab of the Properties pop-up window, select the Read-only check box. Then click on Apply, and click OK. This exercise will allow users to open a file, but will prohibit them from editing the contents of this file and saving the file using the same file name.

10.2 Determining the Number of Required BSA E-Filing Users in Your Organization

Organizations with many people involved in the BSA filing process may want to limit the number of BSA E-Filing users to an appropriate and manageable number. This section provides some practices that may facilitate this optimization.

Form preparers within your organization who are not responsible for submitting or tracking BSA filings or receiving Alerts would only need the Adobe Reader Software and their industry-related BSA forms. These form preparers would not need a user ID or access to BSA E-Filing. This will reduce the time and effort required by your organization in initial preparation and training to use BSA E-Filing. Additionally, this will reduce the amount of time spent by your organization accessing BSA E-Filing and submitting BSA filings, since form preparers would not have to log-on to BSA E-Filing and submit forms; this process could instead be centralized. This centralization will also afford you additional control over your internal BSA filing preparation and submission processes.

Here is an example of how the centralization of BSA E-Filing could work. Let’s say that our hypothetical Main Street Bank has BSA filing personnel in their Biloxi, Dallas, Los Angeles, and New York City locations (as depicted in the illustration on the following page). Submission of the filings is centralized in the New York City location; so all filings are routed internally from the site of preparation via the organization’s internal email system to the New York City location (this internal routing of the filings could also be accomplished through a shared network directory). A Main Street Bank compliance officer, who is stationed at the New York City location, reviews filings from all locations (including New York City), signs them, and submits them to FinCEN via BSA E-Filing. This compliance officer is the only representative of Main Street Bank that would require access to BSA E-Filing (and therefore also a user ID) in this scenario.


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Figure 10.2-1. Centralization Example

Backup filing locations for business continuity purposes: While centralization of your filing submission process may yield efficiencies, having one additional location (remote from the main submission location) that is prepared to submit filings (with connectivity to BSA E-Filing and a BSA E-Filing-trained user) may be desirable for business continuity purposes in the event that your organization’s connectivity to BSA E-Filing is disrupted at the main submission location.

10.3 Streamlining Batch File Upload Processes

Organizations that file BSA forms via batch files can use approaches that may reduce the manual steps required to upload batch files to BSA E-Filing, and customize BSA E-Filing batch filing processes to comply with their internal business process requirements. In order to limit unnecessary routing of batch files internally within your organization and to ensure compliance and control, you can submit batches to BSA E-Filing from the point of compliance approval. If a mainframe system is involved in the generation of batch files, the key challenge will be to minimize the number of steps that are required to move a batch file residing on your mainframe system to a connection point to the Internet (e.g. a user workstation).


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10.4 Filing Naming Conventions and Local Directory Storage

The “Filing Name” fields on the BSA E-Filing Header page are for your use to name a filing in such a manner as to distinguish it from other filings you submit. As such, each file name should be unique. This will be especially useful when using the Track Status feature in BSA E-Filing. You can use naming conventions to optimize your ability to distinguish files from one another, but not to disclose sensitive information contained on the BSA forms. Having a standard naming convention will be even more important if your organization has multiple filers, as filers will want to be able distinguish filings they submitted from ones submitted by other filers within their organization. Conventions that you might consider employing include a filer’s abbreviated name or initials, date of submission, and a sequence number of filings in one day (to the extent that multiple filings are submitted in one day). So, for example the third filing prepared by John Smith on May 28th, 2009 might be named JoSmith05280903, as shown in the graphic below.

Figure 10.4-1. BSA E-Filing Header


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When a BSA E-Filing form is saved, the default directory is the Adobe Reader folder. You may browse the SAVE FORM: Specify Filename pop-up window for another directory location. You could create a separate folder or group of folders specifically for your BSA filings. For example, you might consider creating a root folder with the name “BSA E-Filing,” and sub-directories/folders named “CTRs,” “SARs,” “Alerts,” and “Secure Messages”, respectively.

10.5 Branch Code Naming Conventions

The ‘Branch Code’ field on filing forms is an optional field for your record keeping. Utilizing the branch code field is useful if you prepare filings at multiple locations, but file through a single submission point. Otherwise, if you submit your filings directly to BSA E-Filing you will receive your acknowledgements back directly. If you do not have branch codes already and you have multiple BSA E-Filing discrete submission points, you will need to develop a convention for assigning branch codes to your branches. The Branch Code field is flexible – it accepts both alpha and numeric characters and has a character length of 7 characters. Two straightforward approaches to creating a branch code-naming convention are presented below:

Naming conventions for branch codes: state, town abbreviation and number (1-9 • for cases where there is more than one branch in some towns, for cases where it is the only branch in town the number could simply be 1)

Alternatively, the zip code (5 digits) followed by a number (again, 1-9 for cases • where there is more than one branch in some towns). For example, a branch located in the 06490 zip code area might have a branch code of 069401, as shown in the graphic above.

Once you have chosen a naming convention, it will be critical that you train your branches in using the codes you establish for them. Note that branch codes are not required for submissions, but will be useful if you want to route negative Acknowledgements back to the branch where the CTR was completed.


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