We are trying to figure out what year NAICS Code list is FinCEN using in the new CTR and SAR forms?
Our core processor is using the 2012 NAICS list from Census.gov and our BSA software is using the 2007 NAICS list. The BSA software rep's reasoning is they can't update to the 2012 list because FinCEN has not issued guidance due to the new CTR and SAR forms. We have ran into exceptions because a code from 2007 is not matching to the one from 2012. Any input on this?

Here is the approved FinCEN list. It says 2012:

http://bsaefiling.fincen.treas.gov/docs/NAICS.pdf

Regardless, the FinCEN list is the FinCEN list and they are the only codes that are acceptable.

rlcarey is correct. The only available codes on the CTR & SAR are those on the drop down list as shown on the list he linked. This reflects a yet to be explained decision by FinCEN to not allow filers to use the more recent and more sophisticated 6 digit coding system on the BSA reports.

On a webinar I believe it instructed that we are only to use a 6 digit number for BSA efiling purposes. Is that true?

No.

The field has a drop down list of acceptable codes (linked above). None have more than 4 digits.

Holy carp....I've been doing 6. Our software must be truncating them because i haven't heard boo from anyone regarding it.

I also noticed on the high risk NAICS codes, some of them don't match up with what the BSA efiling codes are. For instance, on the BSA Efiling list, a privately owned ATM would be 5223 but on the High Risk NAICS list the code is listed as 454210. What would account for this discrepency?

Bec, I don't know of any High Risk NAICS code list published by FinCEN. Where is your list from?

It is from NAICS.com

http://www.naics.com/wp/wp-content/uploa...-Codes-List.pdf

Bec, what list are you using that lists privately owned ATMs are 5223? Is it a list provided by your vendor?

I ask because the FinCEN list and the drop down box on the CTR don't list a separate code for Privately Owned ATM, and 5223 is listed for Activities Related to Credit Intermediation (which matches the list at NAICS.com).

I just found that list that I linked to above from NAICS.com, we don't currently use it per say. I notice that the Privately owned ATM code that the list I linked to (the high risk codes list) is for vending machines. The industry standard NAICS code for Privately Owned ATM is the one that you mentioned, Activites related to credit intermediation.