Last week FinCEN announced that they were adding new data elements to the 314a file that you download and scan against member accounts. They reported that they would be adding email, IP address, and website address to an existing field in the file. No additional fields are being added; rather, new data type descriptions and data elements will be added to the existing social security number fields. In the announcement they made it appear as though you would be seeing the changes by September 1st.
We reached out to FinCEN last week asking for clarity on the announcement and they returned our email stating the September 1st date was relative to them being ready for law enforcement to begin inputting the new information, and that the inclusion of the information on the 314a file would not be immediate. They did not give us a date when that would occur. We subsequently reached out to FinCEN yesterday to get technical support relative to the changes and they have replied that the technical specifications will be arriving shortly. No date was given.
No changes will be made to the existing scan until we receive those specifications.
So what if the data begins flowing before the changes are made? If this happens you would see an error message when uploading the file, as the length of the field does not support more than 20 characters. Again, until we get technical specifications we will not be changing the size of this field. Selecting OK on the error is the appropriate response and the scan will continue without a hitch.
It is important that you understand that the primary fields that are being matched are those related to the individuals name and alias name and then subsequently validated against date of birth. If there is a hit on the primary search the system continues and scans the remaining fields. In the event that the primary search does not find a match, the remaining information is not scanned. This secondary scan writes out other information that matches the additional fields to a report which can be used for additional validation. What you report back to FinCEN is the fact that you have a match on the name, not the additional information that actually matches on the file.
We will continue to keep you updated once we receive additional information from FinCEN and have an opportunity to evaluate the development effort for any adjustments we will need to make.