Proposed Rule/Collection Summary

Bank Secrecy Act Currency Transaction Report (BCTR)
Revised Layout and Proposed Additional Data Fields

Prepared by NASCUS Legislative & Regulatory Affairs Department
January, 2016

The Financial Crimes Enforcement Network (FinCEN) is proposing to amend the current Bank Secrecy Act Currency Transaction Report (BCTR) to address reporting limitations.  The amendments would not impose any additional regulatory requirements or result in any substantive change to currency transaction reporting requirements. 

Comments are due to FinCEN by April 4, 2016. 

The notice and request for comments can be found here.

FinCEN revised the Bank Secrecy Act Currency Transaction Report (BCTR) in March 2011.  While reviewing the BCTR for renewal, FinCEN determined the current report contained a number of reporting limitations.  For example, the current BCTR does not provide a method for identifying shared branching transactions.  In response to its findings, FinCEN is proposing to make the following changes to the report:

  • To support recording the dollar amount of the transaction at the transaction location, cash-in and cash-out fields have been added to Part III.
  • A new Part IV, has been added to record the entity filing the report through the BSA E-Filing System.
  • A check box has been added to Part III to indicate when the information in Part IV is the same for Part III. This change will reduce the burden for filing the BCTR in those cases where the filer and transaction locations are the same.
  • In Part I, Item 2d has been changed from “Courier Service (Private)” to “Common carrier” to reflect defined terminology. 
  • Define “teller” for BCTR purposes as “an individual employed by a covered financial institution that accepts currency in the normal course of business at the covered financial institution.”

In addition, FinCEN invites comments on the following:

  • Whether the collection information is necessary for the proper performance of the functions of the agency, including whether the information shall have practical utility;
  • The accuracy of the agency’s estimate of the burden of the collection of the information;
  • Ways to enhance the quality, utility, and clarity of the information to be collected;
  • Ways to minimize the burden of the collection of information on respondents, including through the use of automated collection techniques or other forms of information technology;
  • Estimates of capital or start-up costs and costs of operation, maintenance and purchase of services to provide information; and
  • The proposed definition of the word “teller.”