7 Filing Regulatory Reports

How to file an approved report to the FinCEN's BSA E-Filing system, uploading the acknowledgment into USSAR Cloud Service, and completing the SAR process is described here. Only users mapped to the role of Super User and Admin User can generate an E-file.

When a report is created in the application, the report details are entered and then submitted for approval. After analysis, an Analyst submits the report for the approval, Supervisor validates the report details, and either approves, rejects, or closes the report.

If the supervisor approves the report then the report is available for E-file generation. The generated E-file is submitted to FinCEN's BSA E-Filing System. The E-file is validated by FinCEN and an acknowledgment (XML file) is generated. Then the acknowledgment file is uploaded into the USSAR Cloud Service. The USSAR Cloud Service associates the FinCEN returned BSA Identifier to each SAR within the E-file. By this, the SAR process is marked as completed.

Workflow for Filing the Regulatory Report

The following figure illustrates the workflow of E-file in the USSAR  Cloud Service:

following figure illustrates the workflow of E-file in the USSAR  Cloud Service

 

Topics:

·        Searching Approved Reports 

·        Generating E-File 

·        Downloading  E- Files 

·        Submitting E-Files at FinCEN 

·        Downloading E-File Acknowledgments from FinCEN 

·        Uploading E-File Acknowledgments into USSAR Cloud Service 

·        Rejecting Reports from E-file 

·        Completing the SAR Process 

Searching Approved Reports

Use this pane to search the required approved reports using the search parameters. Super Users and Admin Users can search, file, reject, or close approved reports.

To search for approved reports, follow these steps:

1.     On the Regulatory Report List page, click File Reports. The Approved Report Search page is displayed with the list of all approved reports.

2.     If you want to search for the specific report in the list, then enter the search parameter.

The following table provides the  Approved Reports Search Bar fields and descriptions.

Table:   Approved Reports Search Bar fields and descriptions

Fields

Description

Report Name

Enter the report name.

Jurisdiction

Select the jurisdiction from the drop-down list.

Case ID

Enter the Case ID for the report.

Approved By

Enter the name of the approver.

Approved Date From

Select the date from the calendar. Use this criterion to filter reports approved on or after this date. For example, reports approved on or after July 27, 2019.

You can either perform a range search using Approved Date From’ and Approved Date To or use them independently.

Approved Date To

Select the date from the calendar. Use this criterion to filter reports approved on or before this date. For example, reports approved on or before July 27, 2019.

Created By

Select the user role(s) from the drop-down list to search for reports created by.

3.     Click Go. The relevant report list is displayed.

Generating E-Files

After the status of a regulatory report changes to Approved, you can generate the E-file for those reports and upload the resultant .xml file into the FinCEN’ BSA E-Filing System. When an E-file is generated, an attachment zip file is created for the E-file with a .csv file in it. This .zip file is only available if attachments were associated with any SAR within the E-file.

To generate an E-file, follow these steps:

1.     On the Approved Report Search List page, select the required report or reports for which you want to generate an E-file.

2.     Click Generate E-file Generate E-file. A confirmation message is displayed. The status of the regulatory report changes to E-file Generated.

3.     The reports on which Generate E-file action is taken are moved from the Approved Reports list to the E-file list.

NOTE:   

·        If you try to generate an E-file for the same report(s) which is already locked by another user, an error message is displayed.

·        If you try to E-file or reject a report which is already locked by another user, an error message is displayed.

·        If you try to E-file a report which is already generated or rejected, an error message is displayed.

 

Downloading E-Files

After an E-file generated action is taken, the USSAR  Cloud Service generates a .xml file with its content formatted according to FinCEN specifications for electronic filing. You must save this .xml file and submit to FinCEN’s BSA E-Filing System.

Use the E-file Summary tab to manage the generated E-files for searching and downloading E-files to submit to the FinCEN.

To download the E-files, follow these steps:

1.     On the E-file Summary tab, enter the search parameters.

The following table provides the  E-file Summary  fields and descriptions.

Table:   E-file Search Bar Field Descriptions

Fields

Description

Report Name

Enter the report name.

Jurisdiction

Select the jurisdiction from the drop-down list.

Case ID

Enter the case ID for the report.

E-file Generated By

Enter the name of the E-file generator.

E-file Generated Date From

Select the date from the calendar. Use this criterion to filter E-file generated on or after this date. For example, E-file generated on or after July 27, 2020.

You can either perform a range search using E-file Generated Date From’ and E-file Generated Date To or use them independently.

E-file Generated Date To

Select the date from the calendar. Use this criterion to filter E-file generated on or before this date. For example, E-file generated on or before July 27, 2020.

2.     Click Go. The relevant E-file list is displayed.

3.     On the E-file list results page, select a record and click E-file E-file in the E-file column. A File Download window prompts to Open or Save the E-file. Click Save to download the E-file.

4.     To view the E-file details, select a record in the Details column, and click Details Details . The E-file Details pane is displayed with the number of reports included in the selected E-file.

 

Submitting E-Files at FinCEN

After the E-file is generated, you must file them with the FinCEN’s BSA E-Filing System which in turn generates an acknowledgment or (XML) file.

To submit the E-file at BSA E-Filing System, follow these steps:

1.     Log in to the BSA E-Filing System website.

2.     From the left-hand side menu pane, click New Reports, and select File Batch FinCEN SAR. An Open an Existing Form window is displayed. 

3.     Click Open New Form. A BSA E-Filing SAR Batch Form is displayed.

4.     Enter the BSA E-Filing SAR Batch Form fields.

The following table provides the  BSA E-Filing SAR Batch Form  fields and descriptions.

Table :   BSA E-Filing SAR Batch Form

Fields

Description

Filing Name

Enter the filing name.

There is no specific requirement for the name of the filing. It is recommended that it must be a unique name as this can be used to identify the E-file on the BSA E-Filing system after submission.

Batch File

Click Add to attach the E-file that was downloaded from the USSAR  Cloud Service. NOTE: The E-file must be in .xml format.

Attachments File

Add the E-file attachment .zip file that was downloaded from the USSAR Cloud Service along with the E-file.

Number of Forms in Batch

Enter the number of individual SAR reports in an E-file.

5.     Click Sign with PIN and enter the title and date in the respective fields. The following message is added to the header and footer of the document: This form has been signed with a PIN and can­not be altered.

NOTE:   

This is the unique identifier assigned by BSA and FinCEN to ensure only authorized individuals are submitting SAR filings.

 

6.     Click Save. The filled BSA E-Filing SAR Batch Form is saved. After you save the form, the Submit button is enabled.

7.     Click Submit. A confirmation window displays the following message: We have received your submission. Please confirm the following information and retain it for your records. Please track the status of your submission using the 'Track Status' function in the BSA E-Filing system.

The status of a submitted E-file can be one of the following:

§       Transmitted

§       Transmitted with Warnings

§       Rejected

8.     Click the Accepted with Warning or Rejected status hyperlink in the Status column of Track Status page to view the submission errors on the E-file that are in Accepted with Warning or Rejected status.

9.     Click OK. The E-file is successfully submitted at FinCEN.

 

Downloading E-File Acknowledgments from FinCEN

When the BSA E-Filing System Track Status page shows that the submitted file has been acknowledged, you can retrieve an acknowledgment file from the BSA E-Filing System Secure Messaging center. You must save this acknowledgment .xml file and upload it into the USSAR Cloud Service.

NOTE:   

An acknowledgment file is not generated when an E-filing is rejected.

 

To download the acknowledgment file from BSA E-Filing System, follow these steps:

1.     Log in to the BSA E-Filing System website.

2.     On the Secure Messaging, select View Inbox to view the list of acknowledgments.

3.     Click the Subject of the required acknowledgment. A BSA E-Filing Secure Message Reply Form is displayed.

4.     Click View/Save Attachment. An Acknowledgment (XML) file window is displayed.

5.     Click View/Save to download the XML file in your system.

 

Uploading E-File Acknowledgments to USSAR Cloud Service

After downloading the acknowledgments from BSA E-Filing System, you can upload the acknowledgments in the USSAR Cloud Service. After you upload the acknowledgment (XML) file, the file is then parsed to retrieve the BSA Identifier that is assigned by FinCEN to each report. This BSA Identifier is then added to the report record.

To upload the acknowledgment, follow these steps:

1.     On the E-file Summary page, go to the E-file List pane, select the record for which you want to upload the acknowledgment.

2.     Click Upload Acknowledgment Upload Acknowledgment. An Upload Acknowledgement window is dis­played.

3.     Enter the Upload Acknowledgement fields.

The following table provides the  Upload Acknowledgement Form  fields and descriptions.

Table:   SAR Acknowledgment Window fields and descriptions

Fields

Descriptions

E-file Name

The name of the E-file.

NOTE: This field is auto-generated

Ack Updated By

The name of the user role who is updating the acknowledgment.

NOTE: This field is auto-generated.

Ack Received On

Select the date from the calendar on which the acknowledgment was received.

Ack Number

Enter the acknowledgment number.

EFile Comments

Enter the required comments.

Logical File Name

Enter a logical file name for the acknowledgment.

4.     Click the Click here to upload a File icon to upload the XML file downloaded from the BSA E-Filing System.

5.     Click Attach File and click Save. A confirmation message is displayed.

6.     Click OK. You are navigated back to E-file List results.

NOTE:   

·        After you upload the acknowledgment file for an E-file, a BSA ID is associated with the respective report.

·        After you upload the acknowledgment file successfully into the USSAR Cloud Service, the XML file can be viewed and saved from the E-file list results.

·        When you try to upload an acknowledgment file for an E-file for which an XML file is already uploaded, a warning message is displayed.

·        When an upload acknowledgment action doesn’t pass the validation check, an error message is displayed.

 

Rejecting Reports from E-File

You can reject reports from an E-file before completing the SAR process. After a report is rejected from an E-file, it is removed from the reports list and the status of the rejected report changes to Rejected from E-file.

For reports that are not rejected, a new E-file is regenerated. If the acknowledgment file is already uploaded, you can complete the SAR process of the regenerated E-file by clicking Complete SAR Process.

You can correct a rejected report and resubmit for Super User or Administrator's approval. After the corrected report is approved, you can follow the workflow of filing a regulatory report all over again. Subsequently, while uploading the acknowledgment (XML) file received from FinCEN into the USSAR Cloud Service, a new BSA Identifier overwrites the previously associated BSA Identifier of the rejected SAR(s).

After an E-file is uploaded and accepted by FinCEN, you cannot reject SARs from the E-file until the acknowledgment file is uploaded and parsed. If you reject a report after submission but before processing the acknowledgment files there will be a mismatch in the files referenced in the acknowledgment file and the current E-file. If a report is rejected before uploading the acknowledgment into the application, then you have to re-submit the E-file at FinCEN’s BSA E-Filing System to get the latest acknowledgment file.

To reject the SARs from an E-file, follow these steps:

1.     On the E-file Summary page, go to the E-file List pane, select the E-file. The Report List for the selected E-files is displayed.

2.     Select the report or reports you want to reject from the E-file and click Reject Reject. The rejected reports are removed from the E-file List results.

Completing the SAR Process

After uploading an acknowledgment into the USSAR Cloud Service, you can complete the suspicious activity reporting process by clicking the Complete SAR Process. The status of all regulatory reports included in the E-file then changes to Filed. After a report is moved to the Filed status it cannot be edited.

To complete the SAR process, follow these steps:

1.     On the E-file Summary page, go to the E-file List pane, select the E-file with acknowledgment.

2.     Click SAR Process Complete SAR Process Complete. A confirmation message is displayed.

NOTE:   

·        If you try to take the Complete SAR Process action before performing the Upload Acknowledgment action, a warning message is displayed.

·        If you try to take the Upload Acknowledgment action on a file for which the SAR process is already complete, a warning message is displayed.

 

Generating Revised Reports

When you download an acknowledgment from FINCEN E-File System and identify there are errors or issues in the reports but they are not rejected. You can update the report by selecting the Correct/Amend Prior Report or Continuing Activity Report option for the report in the Filed status and resubmit an E-File with revised reports into FinCen E-File System again.

When you take the Generate Revised Report action on a report using the Correct/Amend Prior Report Type or Continuing Activity Report option, a new report is created with the same information and the status of the report is Open with Correct/Amend Prior Report Type or Continuing Activity Report type. The report with Open status is available in the Regulatory Reports List. To submit the revised report into the FinCen E-File System again, follow the workflow.

For example, if you have submitted report number 4458 into FinCen E-File System and received an acknowledgment with errors or issues. You have two options to revise the report and resubmit into FINCEN E-File System:

·        Correct/Amend Prior Report Type:  This option is used if any errors are to be corrected in the report. For example, Open Report Number 4458 in the Filed status and click Generate Revised Report. In the Generate Revised Report window, select the Correct/Amend Prior Report Type and save. A copy of Report Number 4458 created with new Report Number 2234 with the same information. The status of the report is Open and the report type is Correct/Amend Prior Report Type. You can access the Correct /Amend Prior Report type in the Report Search and List page. Now follow the workflow and resubmit into FINCEN E-File System.

·        Continuing Activity Report Type: This option is used if you want to add additional information and continue the filed report. For example, open Report Number 4458 in the Filed status and click Generate Revised Report. In the Generate Revised Report window, select the Delete option and save. A copy of Report Number 4458 created with new Report Number 2234 with the same information. The status of the report is Open and the report type is Continuing Activity Report. Now follow the workflow and resubmit into FINCEN E-File System.

To generate a revised report, follow these steps:

1.     On the Regulatory Report List page, open the report with Filed status.

2.     On the Details page, click Details. A Revised Generate window is displayed.

3.     Select the Correct/Amend Prior Report Type or Continuing Activity Report from the Type of Filing drop-down list and enter the comments.

4.     Click Save. A confirmation message is displayed and a new report type is created as Correct/Amend Prior Report Type or Continuing Activity Report with the same information. The status of the report is Open.

5.     Go to Report List and open a newly created report. Make the required corrections to the report and get approved to resubmit into FINTRAC E-File System. The FINTRAC E-File System verifies the report and replaces this report in its system for correction.