It took days to search records for the 7 entities named in the first FINCEN request and now they have sent two new ones.

This is a nightmare to research. Does anyone have any ideas on how to maintain records in a more search friendly manner? We download from FEDWIRE records on incoming and outgoing wires by the day and store on diskette. It took me two solid days or more to search each of those files for the names in the first request. Monetary logs are filed by the day in a paper format. Not an easy way to search. Are these requests going to be frequent happenings? HELP! What is everyone else doing to comply with these requests?????

See this FinCEN thread .

Manual is the only way I know. I have now gotten 4 since last Monday so appears that this is going to be about a daily issue to deal with.....and keep up with what we have done and not done and the deadline! If we have only 7 business days, what are we contacts to do when we are on vacation? No one else has access to my emails when I am out.... I am not at all happy about this new job!

May I also add.......the one I just received was dated 11-4-02! How can I comply with the 7 day rule when they can't even send them timely!!

It's time to go out and walk around the block to cool off!

No easy way. I have actually been entering wire data into an Excel spreadsheet for the past six months. So I can quickly search the file but I still have to take the time to enter the data.
This is clearly one very large fishing expedition. How do you spell Big Brother?
Opinions expressed are my own and my employer definitely does not want to be associated with them.

We got our 4th FinCEN request yesterday afternoon. If they continue to nickle and dime these requests, trickling them in this way, they'll soon have a lot of opposition instead of a genuine spirit of assistance. It takes them a moment to send a request, it takes much, much longer to meet them.

Perhaps the folks driving these lists should be asked to review their personal and family bank statements to determine if any check they wrote or ATM they have used in the last year was in any way connected to a list of banks we produce. Perhaps that would give them a feel for what we're doing here.

I agree with the purpose but this is a joke. I have 4 requests in my inbox this morning as this is turning out to be a nightmare. I think Im going to contact our state banking group and have them try and talk some sense into these people ( I think everyone should). What happened to the Paperwork Reduction Act?

Andy - I think it's time for a letter writing campaign.

What!!!

I recieved five new information requests this morning.

I am all for patriotism but this is out of hand. Does anyone else feel that this amounts to banks conducting the leg work for government agencies. We have been deputized.

FinCEN must do something about this, and soon. My entire bank is up in arms about the barrage of requests!

We are still working to clear the very first request that we recieved on 11-4-02. This cannot continue.

Do we have any indication of what the ramifications are if you decide to ignore the requests?

Frustrated!

HELP!! Can we opt out of this information sharing? If so, tell me how before my bank commits mutiny.

Just got another one! 5 Minutes after I last posted. Opt out is a good one. We could all just have our mail servers bounce 'em back and see how they like it. Oh well, off to do research.

I hadn't checked my e-mail yet when I made my earlier posts. 5-8 were waiting. I am going to have our folks check their time to complete these tasks and will seriously consider complaining about these.

What does it take for FinCEN to send the inquiry, is this a fishing expedition or a serious and credible threat? And what happened to geographic targeting? I thought these were to sent to those applicable to the area. It sounds like we all get the same ones.

OK, let me get this straight, are you speaking of Section 314 of the USA Patriot Act that promotes Information Sharing? I have not received any FINCEN alerts but we also elected NOT to participate in the information sharing since it was a voluntary decision....So I am assuming by the conversation in this thread that each of you have signed on to Section 314 and chose to share information? I just want to make sure that I am not missing something that we should be doing.

Yes, 314(a).

Andy, you prompted a thought when you mentioned tracking time for research - is this stuff reimbursable under Reg. S?

Does anyone have any objections of me sending a link to this thread to my Congressman and Senator?

Because of name and pictures appearing, I did not want to do this if anyone objected.

Back to the important question, anyone know of a way to opt out of this?

Don't get 314(a) and 314(b) confused. You can opt in to sharing information with other financial institutions, but there is no opt in for information sharing with FINCEN. All financial institutions are subject to these requests, if you receive them. I think that there are some institutions that FINCEN has not found yet, or are sending requests to dead e-mail addresses or worse.

In looking at my hard copy mail, I have answered my own question. We are "required" to comply with requests from FinCEN, 31 CFR 103.100. We can elect to share or not share with other financial institutions 31 CFR 103.110. See link OCC Bulletin

You have my permission to send this to your and every other government agency that might have any influence. It would be great if one of us knew how to easily create a list for all senators, rep, state banking chairs, etc. that we all would agree to support. (If it means sending a copy of this thread, then those who do not wish to be included could delete their post.)

It is fine by me and this is a public forum. Mary Beth's blessing is likely one that counts even at that. But remember that we'd want to honor the disclaimers that we are not necessarily speaking on behalf of the bank in here.

That said, once I have some info on the time this is taking, I will likely send some comment letters to ensure the checks and balances to warrant the inquiry are in place and justify our time. I don't know that it would do any good, but I'd feel better.

Andy,
It's great you have the staff at your bank to do the research on all of these FINCEN requests. We are thinly staffed, so that leaves me to do the research. I have had to put all of my other regular work on hold to look all of last weeks' requests as well as the six we have received since yesterday afternoon.

Calculating total dollars spent will be fun, since my "hourly" rate is much higher than our hourly employees. The President of our bank is the Chairman of the Oklahoma Banker's Association this year, so maybe I can convince him to have the OBA complain on behalf of all of the banks in our state. He wasn't happy about it last Friday after I showed him the first three requests we received. One can hope . . .

Anyone else notice that several of the ones waiting for us this morning were sent some time in the middle of the night!?!? Do they work 24 hours a day, or are their computers just automatically sending these things out?

How is everyone checking? From what it sounds like, it is taking a considerable amount of time to research the names FinCEN has sent us. I checked with the person that is apparently checking everything and she says that it's so easy, it takes her usually not more than 5 minutes. I'm really thinking something is being missed!

Is she checking all originators and beneficiaries on all wire transfers you processed in the last six months?

Her systems must be totally automated. Unfortunately, ours are not for anything that is not a "current" account. We get daily reports of closed accounts, by type of accounts (CD, DDA, Savings), but have to pull each day to search for any of these names, which on my count (including the AKA's), is up to 47. Our wires are not currently maintained on any automated spreadsheet for ease of looking up names either, because the person in charge of them prefers a hand written log. Maybe I should have her look through six months worth of wires to make sure our customers (we don't send wires for non-customers) have not received wires from, or sent wires to any of the names on these requests, so she will understand what a pain this has been. It took four days, because the stack for each month is 4-5 inches thick. We will be developing a spreadsheet for the future, if these requests for information continue.