Frequently Asked Questions (FAQs)

This section addresses many of the more commonly asked questions regarding use of the BSA E-Filing System. For additional information, contact the BSA E-Filing Help Desk via telephone at 1-888-827-2778 (Option 6) or e-mail at BSAEFilingHelp@notes.tcs.treas.gov.

These FAQs are organized by category. Click on a category to view the list of questions related to that category; click on a question to view the answer.

Understanding What BSA E-Filing Is and What It Offers
Understanding How BSA E-Filing Operates
Connecting to BSA E-Filing/Forms Viewer
Enrollment
General Filing
Discrete BSA Filing
Batch BSA Filing
Secure Data Transfer Mode (SDTM)

Understanding What BSA E-Filing Is and What It Offers

What is the purpose of BSA E-Filing?

BSA E-Filing allows organizations to electronically and securely file discrete and batched Bank Secrecy Act (BSA) forms. It also allows members of filing organizations to send secure messages to FinCEN (and receive responses where appropriate). Finally, FinCEN can use BSA E-Filing to issue advisories and system updates to the BSA E-Filing user community.

What BSA forms may be submitted via BSA E-Filing?

See Using BSA E-Filing for a list of BSA forms that can be submitted via BSA E-Filing.

How much does participation in BSA E-Filing cost?

Nothing. No direct costs are involved for an organization to use BSA E-Filing. However, indirect costs may be incurred if an organization elects to make changes to its internal BSA filing processes in order to optimize its use of BSA E-Filing.

Can a law firm file BSA forms for a client?

No. A law firm may assist its clients in the preparation of electronic BSA forms for BSA E-Filing, but the client must submit filings on its own behalf.

Can a holding company file for an affiliate bank?

Yes, provided the information on the BSA form reflects the location where the transaction or suspicious activity occurred.

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Understanding How BSA E-Filing Operates

What assistance is available for using the BSA E-Filing System?

Once enrolled in BSA E-Filing, your organization's Supervisory User will be able to access information on the secure portion of the BSA website.

How secure is BSA E-Filing?

BSA E-Filing was designed and developed in strict compliance with Government regulations applicable to Federal computer systems. Various management, operational, and technical security controls have been implemented to protect the confidentiality, integrity, and availability of the system and its resident data.

How do I get started using BSA E-Filing?

Click Become a BSA E-Filer and follow the instructions in each of the four steps to enroll your organization in BSA E-Filing.

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Connecting to BSA E-Filing/Forms Viewer

What Internet connection speed is required to use BSA E-Filing?

A connection to the Internet of at least 56 kbps is required to interact properly with BSA E-Filing. The speed of your connection should accommodate the size of the files you plan to upload to BSA E-Filing.

How can I download the Forms Viewer?

The Forms Viewer is accessible by clicking the Download Forms Viewer link. Download and installation instructions are provided in Step 4 of Become a BSA E-Filer.

What is wrong if, upon attempting to open a BSA E-Filing electronic form, Adobe Acrobat Reader starts up and I cannot display the file?

You may not have installed the Forms Viewer, or a conflict may exist between the Forms Viewer and Adobe Acrobat Reader. Confirm that you installed the Forms Viewer by choosing Start > Programs > ICS Viewer 5.1 > ICS Viewer. If you have not installed the Forms Viewer, it can be downloaded by clicking Download Forms Viewer on the home page. If you have already installed the Forms Viewer, there may be a conflict between it and Adobe Acrobat Reader. Installation of Adobe Acrobat Reader after installing the Forms Viewer has caused problems for some BSA E-Filing users. Deinstalling and reinstalling the Forms Viewer will remedy this problem.

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Enrollment

How do I enroll?

To enroll, click Become a BSA E-Filer and follow the instructions in each of the four steps.

If your organization has already enrolled in BSA E-Filing, contact your organization's Supervisory User to obtain instructions for enrolling yourself as a general user.

What is a Supervisory User?

A BSA E-Filing Supervisory User is a person who has primary responsibility for the filing organization's use of BSA E-Filing. A Supervisory User should be in a position to be cognizant of all BSA filing activities across the entire filing organization. This person should also be knowledgeable regarding the individuals responsible for preparing and submitting BSA filings and the processes by which filings are submitted. Within the secure portion of the BSA E-Filing website, Supervisory Users have access to functionality not available to regular users, including the ability to initiate the enrollment of new users, manage user access (i.e., assign privileges), update filing organization information, and track the status of filings submitted by all users from the organization.

What is the Filing Organization Enrollment Code, and how do I get one?

The Filing Organization Enrollment Code uniquely identifies your organization within BSA E-Filing. It is created when the designated Supervisory User enrolls your organization in BSA E-Filing and is required to enroll any subsequent users. If you are a regular BSA E-Filing user or the backup Supervisory User, you should contact your organization's Supervisory User to obtain your Filing Organization Enrollment Code. If you are a Supervisory User, this code may be obtained from the secure portion of the BSA E-Filing website.

What is a TCC (or Transmitter Control Code) ID?

A TCC ID is assigned to an organization after FinCEN has approved its application to become a batch filer. The first record of every batch file submitted by the organization must include the TCC ID. Discrete filers do not have a TCC ID and may disregard this field during the enrollment process.

What is an EIN (or Employer Identification Number)?

The EIN, also known as a Federal Taxpayer Identification Number (TIN), is a nine-digit number assigned by the IRS to uniquely identify business entities.

What is an MICR (or Magnetic Ink Character Recognition) number?

The MICR number, sometimes referred to as the routing number, is an eight- or nine-digit code that depository organizations enter in field 43 of the discrete CTR form. You may leave this field blank when enrolling your organization in BSA E-Filing if it is not a depository organization.

What is the DUNS number?

The Dun & Bradstreet DUNS number is a unique nine-digit identification sequence assigned by Dun & Bradstreet to single business entities that links corporate structures together. This number is requested, but not required, when you request a user ID and password because it helps the vetter complete the identity and employment verification process.

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General Filing (questions may apply to any type of filing)

Must magnetic media specifications still be adhered to?

Yes. Your filings must meet BSA E-Filing electronic filing requirements (which supersede and incorporate the magnetic media specifications). These requirements are available at the FinCEN website (http://www.fincen.gov/). Instructions for entering information into the forms electronically are generally the same as they were for paper filing, but they do vary somewhat. An example is item 14d on the CTR form. With the paper form, you could enter "N/A" in certain situations; however, this is not always an option with BSA E-Filing. Check the Help text on any items in question when entering data on the BSA form.

Can my BSA E-Filing electronic filings satisfy my state filing requirements?

No. BSA E-Filings only allow users to satisfy selected Federal BSA filings requirements. See Using BSA E-Filing for a list of BSA forms that can be submitted via BSA E-Filing. Printed and/or electronically saved copies of the filings submitted via BSA E-Filing may be retained to meet Federal filing records retention requirements.

Can a partially completed BSA form be saved and completed at a later time?

Yes. You can save a BSA form at any stage of completion and then reopen it later to complete or submit it.

Must CTRs (Currency Transaction Reports) be filed within 15 days after the transaction date (as with paper filings) or within 25 days (as for batch filings)?

In accordance with BSA E-Filing electronic filing requirements, CTRs will be considered on time if received by the ECC-D no more than 25 calendar days after the date of the transaction.

What other BSA forms are available for filing via BSA E-Filing?

Check this site regularly for announcements regarding the availability of new forms. Currently, you can file:

CTRs (Currency Transaction Reports)
DEPs (Designations of Exempt Persons)
SARs (Suspicious Activity Reports)
SAR-MSBs (Suspicious Activity Reports - Money Service Businesses)
SAR-SFs (Suspicious Activity Reports - Security and Futures Industries)
CTRCs (Currency Transaction Reports by Casinos)
SARCs (Suspicious Activity Reports by Casinos and Card Clubs))

Am I still required to keep filings for five years?

Yes. You are still required to keep filings for five years. You have the option of storing them as paper filings, saving them to your computer's hard drive or a network drive, or storing them on magnetic media. You will not be able to retrieve your filings from BSA E-Filing once you have submitted them. BSA E-Filing does not store filings; it only transmits them to the ECC-D.

Can I submit a printed version of the electronic Bank Secrecy Act (BSA) E-Filing BSA Form to the Enterprise Computing Center - Detroit (ECC-D)?

No. The ECC-D will not accept printed versions of the forms produced by BSA E-Filing. This type of submission does not meet the reporting requirements under Title 31, Part 103 of the Bank Secrecy Act.

How long does BSA E-Filing retain administrative data (i.e., Acknowledgment, Alert, and Track Status data) associated with electronic BSA filings?

BSA E-Filing retains administrative data as follows: (1) Acknowledgment data are retained for 30 days after being opened or 60 days after being posted, whichever comes first; (2) Alert data are retained for 30 days after posting; and (3) Track Status data are retained for 365 days after achieving "Accepted" or "Rejected" status. It is highly recommended that you perform electronic and/or hard-copy archival of administrative data to support your organization's archival requirements.

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Discrete BSA Filing

What is a discrete BSA filing?

Discrete filings refer to BSA forms that are submitted one at a time rather than in aggregated batches.

How does discrete BSA E-Filing differ from paper-based BSA filing?

When filing discrete electronic forms via BSA E-Filing, you complete electronic forms on your computer (rather than creating hard copies by hand or using a typewriter or computer) and submit them electronically to BSA E-Filing (rather than mailing hard copies to the Enterprise Computing Center - Detroit). (Please see the related detailed instructions in the BSA E-Filing User Manual on the secure portion of the site.) Unlike with paper forms, you do not have the ability to enter information outside of a form's allotted space. The content of a BSA E-Filing discrete filing must meet the same specifications that existed for magnetic media filing of specific BSA forms. These specifications are available on the FinCEN website.

Can I group my discrete BSA filings and submit them all at once?

No. This functionality does not exist in BSA E-Filing. Each discrete BSA filing must be individually signed, saved, and submitted to BSA E-Filing. If you find that you are submitting a large quantity of discrete filings each week, you might consider the merits of submitting batch filings.

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Batch BSA Filing

What is a batch BSA filing?

A batch BSA filing is an electronic file created by a batch file creation software program (either developed in-house or bought from a third-party vendor). The file typically contains multiple BSA forms (although it is possible for a batch to contain just one filing).

How do I know what batch BSA filing format I should be using?

You should ensure that your batches comply with the BSA E-Filing electronic filing requirements. These specifications are available on the FinCEN website. For tips on how to ensure your batches remain in the proper format throughout the download process from your mainframe to a PC in preparation for uploading to BSA E-Filing, refer to section 6.3, "Batch Filing", in the BSA E-Filing User Manual on the secure portion of the BSA E-Filing website.

If we apply to use BSA E-Filing and do not currently file batch filings, do we need to separately apply for authorization to file batches before doing so?

Yes. You must apply for and receive authorization before you can file batches via BSA E-Filing. The application process for filing batches is handled through FinCEN or the BSA E-Filing Help Desk. The instructions for applying to file batches are available in the BSA E-Filing System Batch File Testing Procedures guide.

Where can we get help determining what modifications we need to make to our bank's procedures to use the system?

Detailed information is available on the secure portion of the website. In addition, Take a Tour, available on the BSA E-Filing public site, provides an overview of the BSA E-Filing System.

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Secure Data Transfer Mode (SDTM)

What is SDTM?

SDTM is a secure mechanism for transferring batch submissions from your organization's internal server to the BSA E-Filing server.

What are the advantages of using the BSA E-Filing SDTM?

The batch submission process can be automated such that user intervention/involvement is minimized.

What is the difference in the file format previously used on tape and diskette submissions and the file format used for SDTM submissions?

None. They are identical. Files previously formatted for use on tape and diskette submissions are accepted by the SDTM process without any changes. However, at present, the BSA E-Filing System accepts only ASCII-formatted batch submission files using SDTM.

What are the differences between the BSA E-Filing electronic filing requirements and the specification for SDTM batch submission?

None. SDTM submissions must meet the same requirements.

Are there any restrictions or limits on the size or number of submissions in a batch in SDTM transfers?

The restrictions for SDTM batch submissions are the same as those for manual batch submissions. There are no additional restrictions, nor are there any fewer restrictions. Both types of batch submissions must meet the BSA E-Filing electronic filing requirements.

How will Currency Transaction Report acknowledgment files be returned when SDTM is used for CTR submissions?

One file will be sent to the server that submitted the CTR batch file for each CTR batch file submitted. The name of the acknowledgment file will be composed of the name of the CTR batch file followed by ".ACKED". For example, if the CTR submission is named "CTRST.20061011062411.ANYBANK.002", the corresponding acknowledgment file will be named "CTRST.20061011062411.ANYBANK.002.ACKED".

What are the costs associated with the use of SDTM?

The cost will depend upon what software is already in use by the financial institution and the availability of either a VPN appliance or the Connect:Direct Secure+ option. SDTM subscribers must use software that can exchange data with the Sterling Commerce Connect:Direct application with client authentication enabled. Client authentication requires the use of a third-party signed certificate for a trusted certificate authority. The cost of this software is dependent on the platform on which it is deployed, and the cost of the certificate is dependent upon the third-party certificate authority chosen. SDTM subscribers must have a VPN appliance that is compatible with the BSA E-Filing VPN appliance or use Connect:Direct with the Secure+ option. In addition, there may be costs associated with the setup, test, and maintenance of this capability.

What needs to be done to start using SDTM if we already file batch files using magnetic tape, diskette, or BSA E-Filing?

You will need to contact our Help Desk at 1-888-827-2778 (option 6) or BSAEFilingHelp@notes.tcs.treas.gov so that our SDTM systems engineering team can exchange control information with you and perform testing on the BSA E-Filing User Test system. Once testing has been completed successfully, additional control information will be exchanged and the production tables will be updated to enable communications tests. Tests will be conducted to ensure that files can be exchanged securely, submissions are acceptable to the ECC-D, acknowledgment files can be sent from BSA E-Filing to the subscriber, and acknowledgment files can be processed successfully by the subscriber.

Is the Sterling Commerce Connect:Direct software (with Secure+, client authentication, and TLS_RSA_WITH_AES_256_CBC_SHA Encipherment Suite or a VPN appliance) the only software that can be used to exchange files with the BSA SDTM system?

No. Other software systems may be used as long as the subscriber is able to communicate with the Sterling Commerce Connect:Direct software (with Secure+ client authentication along with TLS_RSA_WITH_AES_256_CBC_SHA Encipherment Suite or a VPN appliance). Note: The Sterling Commerce Connect Select product is not usable with BSA E-Filing unless VPN is used because it does not provide client authentication and does not support TLS_RSA_WITH_AES_256_CBC_SHA encipherment.

If we convert to SDTM for batch filing, can we still file batches manually? Can we use both methods (manual and SDTM) at the same time?

Yes. Remember that the acknowledgment files from CTR batches filed manually are only available by logging into the BSA E-Filing System, opening the submitting user's BSA secure inbox, and detaching the acknowledgment file manually. Acknowledgment files for SDTM batch submissions will be sent back to the server from which they originated. Care must be taken when filing both ways to ensure that duplicate submissions are not sent to the ECC-D.

If we submit using SDTM, how will we be notified that a submission has been accepted or rejected?

You will receive an unclassified email with the BSA tracking number and a status of either "Accepted" or "Rejected", as is currently the process for manual submissions.

How will we know that the acknowledgments are available to be processed?

The SDTM server can be programmed to launch an application on your SDTM server with the name of the acknowledgment file sent to the server. Alternatively, your server could be programmed to "watch" for new files and process them when they arrive.

Is there any additional tracking provided for SDTM batch submissions?

Yes, an additional role (SDTMBatchFiler) can be assigned to any BSA E-Filing user. However, requests for assignment of this role to users must be placed with our Help Desk at 1-888-827-2778 (Option 6) or BSAEFilingHelp@notes.tcs.treas.gov, as this role cannot be assigned by Supervisory Users at this time. This role provides access to one additional report (SDTM Batch Submissions View SDTM Batch Submissions), which provides the following information for each SDTM batch submission: BSA E-Filing Tracking ID, Form Type, Date Received, Date Opened, Owner, Number Filings (in batch submission). This report is the only report that provides a count of the number of filings in SDTM batch submissions. This report is restricted to SDTM batch submissions and not available for manual batch submissions.

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