Q: When should I save the copy of the FinCEN CTR that is being filed using the BSA E-Filing System?
A: A BSA filing may be saved at any stage of completion and then reopened at a later time to complete and submit into the BSA E-Filing System. You must electronically save your filing before it can be submitted into the BSA E-Filing System. NOTE: The BSA E-Filing System is not a record keeping program. When saving a BSA filing, users must save the filing to their computer, network, or other appropriate storage device. For additional information about recordkeeping requirements under the BSA, please refer to 31 CFR § 1010.430(d) and FAQ #11.
Please note that the BSA E-Filing System will log filers off the system after a certain time period if there is no action within the account, even if the filer is working within the FinCEN CTR. For that reason, FinCEN strongly recommends that filers download the FinCEN CTR template, log out of BSA E-Filing, complete the FinCEN CTR off-line, and then log back into BSA E-Filing to upload and submit the report.
This FAQ was obtained from FinCEN’s website, FinCEN CTR FAQs section, which may be found here: