Update on FinCEN 314(a) Format Changes

You may have been made aware in December that FinCEN is updating its 314(a) file download specifications to take effect on March 1, 2025.

We have reviewed the download specifications document and programmed for these changes. We’ve requested test files from FinCEN to QC these changes and ensure a smooth transition.  After multiple requests we are still unable to obtain test files from FinCEN.

CU*SOUTH is standing ready to continue as soon as FinCEN provides the data needed. This was brought to our attention by credit unions in the network initially, so if you receive any correspondence from FinCEN regarding the 314(a) file download specifications, we ask that you keep us informed, as they may not communicate directly with us.

We will continue to keep you updated as we receive information, but please understand that we will not be able to implement any changes without the opportunity to perform appropriate testing.

**UPDATE 2/10/2025 9:10 AM CT** FinCEN has let us know they will NOT be providing test files, and all correspondence regarding the updates to the 314(a) scan will route through credit unions.

Please pass along any information you receive regarding the 314(a) updates to [e-mail].

**UPDATE 2/21/2025 1:40 PM CT** We appreciate the strong response we received to this initial alert with information regarding the 314(a) scan.  Unfortunately, as FinCEN has still not released test files to credit unions, we are not able to validate the changes we have made.

Due to this, we do not anticipate we will have the project completed by the March 1st deadline. This may require credit unions to manually scrub the lists against the database up until we receive a test file and program accordingly.

Please continue to reach out with any correspondence you receive from FinCEN regarding this topic.

**UPDATE 2/25/2025 2:15 PM CT** Thank you to the many credit unions that reached out to provide us the latest update from FinCEN.  We have received the test files required to continue the programming work.  We will update the alert once we have a target implementation date.

**UPDATE 2/28/2025 11:25 AM CT** We have been working diligently to complete our testing but with the delay in receiving the test files we have not yet been successful in completing our changes and will therefore not be ready for implementation by the March 1 deadline.  If you try to upload 314(a) files before we are done, you may receive an error message such as “Server returned SQL error (Data truncation)” which will prevent you from completing the upload. We will update this alert again next week with a status update on our progress.

**UPDATE 3/4/2025 3:15 PM CT** We have been made aware of credit unions receiving errors when trying to upload the newly formatted FinCEN 314(a) reports through CU*BASE.  We would like to remind credit unions that this functionality will result in errors until our project is put into production.  The project has passed QC testing and have a tentative date of 3/11 or 3/18 to implement this project into production.  In the meantime, credit unions have the option to search the Non-member, Active member, and Closed member, data base to search for any potential matches.  We will be sure to continue to update the alert once we have a final date of implementation.

**UPDATE 3/14/2025 9:10 AM CT** We will be implementing the project to address the FinCEN 314(a) file format changes on 3/18/25.  Once this project is implemented, credit unions should no longer experience errors when uploading the document and completing the scan.  If after the 3/18 date credit unions continue to experience errors, please reach out to [e-mail].

**UPDATE 3/18/2025 11:00 AM CT** As of 3/18/2025, Project # 65496 has been implemented. Credit unions now can upload the FCPERSON and FCBUSINESS files to complete their 314(a) scan requirements without error. Note: You may receive an error that a column is too long. If this is the case, we recommend that you re-download the file from the FinCEN portal and try to complete the scan again. Reports will show the current date of the completed scan. If you are scanning a previous report, you can make a note on the report that the file was for a previous date.