On March 1, 2005, the Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) released the Secure Information Sharing System (SISS) for Section 314(a) information. Financial institutions should be receiving biweekly e-mail notifications about new information that has been posted on the SISS Web site for their review. Beginning with the June 30, 2005, Federal Financial Institutions Examination Council (FFIEC) Call Report, institutions will be allowed to include up to four points of contact – an increase from the previous limit of two – for USA PATRIOT Act Section 314(a) reviews.
Financial institutions are responsible for ensuring that staff working on 314(a) issues are listed as points of contact. FinCEN will use the contact names to verify users before beginning discussions about 314(a) data or other issues. The additional contacts on the Call Report increase the number of employees that an institution may use to work with FinCEN on 314(a) matters.
Financial institutions are reminded that third-party service providers cannot be listed as points of contact. A financial institution can share the 314(a) data with the service provider after it is received, subject to confidentiality agreements. SISS can only be accessed by those individuals who have been designated as Section 314(a) points of contact.
Changes to Section 314(a) point of contact information must be made through the quarterly Call Report. For more information, contact 1-800-688-FDIC or firstname.lastname@example.org.
Banks receiving FinCEN information by fax will continue to receive information by fax unless they ask to receive the Section 314(a) notifications via e-mail.
Please distribute this information to the appropriate personnel in your institution. For further information, please contact FinCEN's 314 Program Office at 1-800-949-2732, option 2, or email@example.com.
||Michael J. Zamorski
Division of Supervision and Consumer Protection