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Important Notice for Financial Institutions FinCEN E-Filing Transition Period July 1st - July 8th 2012

July 17, 2012

Since July 1, FinCEN's E-Filing system has received over 365,000 reports from financial institutions. In the two weeks prior to July 1, FinCEN received 5,000 new E-Filing registrations. This volume compares to a weekly average of 500 in 2012. During June 18-29, FinCEN's helpdesk services received over 5,000 calls and e-mails compared to 1,000 calls and e-mails during a typical week. A combination of increased volume of new registrations and the normal volume of E-Filing, as well as difficulties caused by extensive East Coast power outages, resulted in delays, failed login sessions and, in a few cases, mistaken rejections of properly filed reports. The BSA E-Filing System is functioning properly and has completed the processing of backlog data.

Institutions with rejected filings should have received an electronic notification and should re-file their reports accordingly. Some institutions may have been unable to access the E-Filing system, through no fault of their own, during this period and their filings may have been delayed. State and Federal Financial Regulators have been informed of the unique circumstances that arose during this period. Examination staff should consider these events when reviewing the financial institution's filings for this period.

As a reminder and reflected in FinCEN's February 24, 2012, Notice to Financial Institutions on the Exemption Process,1 FinCEN acknowledges that financial institutions may at times, and on limited occasions, have ad hoc administrative difficulties in submitting BSA reports to FinCEN electronically within the required timeframes. When such difficulties arise, financial institutions should contact FinCEN's Regulatory Helpline at 1-800-949-2732 to make FinCEN aware of the compliance concerns and to determine the best option to ensure the required information is submitted in the most expedient manner.

E-Filing enhances the quality of FinCEN's data, improves analytical capabilities, and ultimately gives law enforcement access to the data in an expedient manner. FinCEN appreciates the patience shown by filers who faced delays or mistaken rejections and looks forward to serving the E-Filing community as we work together to protect the integrity of the financial system.