Question & Answer

Question: We're having quite a discussion about the $3,000 log we have to keep. Are you absolutely sure we no longer have to keep the log? We heard from one attorney that it is still part of the BSA Law. And our examiner asks for it!

Answer: We get this call at least once every month. And have since FinCEN / U.S. Treasury did away with the requirement on October 17, 1994! You may see for yourself in the Federal Register, 59FR 52250 - Monday, 10/17/94. Your financial institution may have a procedure in place they are reluctant to do away with - it provides an excellent audit trail, even though it's a pain to maintain. However, it is no longer a requirement under the Bank Secrecy Act. Click here to view the Federal Register pages.

Copyright © 2000 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 9, No. 12, 1/00