How does FinCEN process SAR filings? How long does it typically take to process these filings?

Important Note: This article does not provide official guidance and has not been reviewed or approved by FinCEN. It’s based on Hummingbird's experience and observations of the FinCEN process.

The following guidance from FinCEN shares their guidance for turnaround time:

"Filing organizations send batch files to the BSA e-Filing System and an acknowledgement file is sent back to the filing organization within 48 hours containing the official BSA Identifiers for each filing within the batch along with any errors associated with the filings."

When you submit a filing, it actually goes through three stages on FinCEN's side. The first stage of acceptance is noted by an email from FinCEN. Following that, there are two more stages at FinCEN that need to occur before it’s fully acknowledged.

The three stages are:

1) Acceptance

After a filing is sent, an automated process within the BSA e-Filing system runs through a set of validations. After these validations are conducted, an email is sent to the filing institution which notifies them of acceptance or rejection. Based on our discussions with the BSA Help Desk and our own testing, this usually takes about an hour.

Hummingbird currently does not receive this email from FinCEN, as it is sent directly to the filing institution. As a result, the filing status shown in Hummingbird does not update at this time.

2) Transmission

Every morning, a process within the BSA e-Filing system sends off all accepted filings to FinCEN for processing. This process provides no notification to either the filing institution or Hummingbird, but it does change the status of the filing in the BSA portal from Accepted to Transmitted.

3) Acknowledgement

Once processing is completed by FinCEN, the BSA e-Filing system is notified and sends out acknowledgement notifications. When Hummingbird receives these notifications, we update the status of the filings in our web interface. The acknowledgement also triggers an email from the BSA e-Filing system to the filing institution notifying them of the acknowledgement.

As quoted above, the guidance is that a response should be received within 48 hours. However, when we've spoken to the BSA Help Desk, they've said that at times, due to resource limitations, the FinCEN processing can take longer. Their guidance was to expect end-to-end processing to take up to 72 business hours (3 business days) and potentially longer during weekends or holidays.

Note that this FinCEN processing time is required for all filings, including discrete filings using the PDF.

The FinCEN SDTM guidance document includes more detail, though it's admittedly quite technical.

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