Q: What is the timeframe for filing the FinCEN CTR? I have seen both 15 and 25 days referenced.
A: FinCEN regulations have consistently maintained a regulatory requirement that CTRs be filed within 15 days. The 25-day period was implemented, in connection with receipt of magnetic media files (ended December 2008), to account for physically transporting (shipping) the magnetic media to the processing center in Detroit, Michigan. FinCEN understands that this business practice had continued with respect to batch e-filing, particularly considering previous public guidance referencing the 25-day period.
In light of the comments received and acknowledging that some financial institutions may have needed to change their business processes to become compliant with the rules, FinCEN determined that it would temporarily maintain the 25-day compliance period referenced in its earlier specifications until March 31, 2013, for those filers that needed to update their systems in order to be in compliance with the established regulatory requirements. This temporary extension to the filing requirements was to allow sufficient time for filers to adjust submission schedules to meet established regulatory requirements.
As of April 1, 2013, all FinCEN CTRs must be filed within 15 calendar days of the reported transaction(s).
This FAQ was obtained from FinCEN’s website, FinCEN CTR FAQs section, which may be found here: