The Clearing House Association submitted a comment letter to FinCEN on its proposal to require electronic filing of all Bank Secrecy Act reports beginning on June 30, 2012. TCH supports electronic filing, but believes that this proposal must be analyzed in conjunction with the new E-file formats for the Currency Transaction Report (“CTR”) and the Suspicious Activity Report (“SAR”). Because these new formats will require banks and other filers to make extensive systems changes, TCH believes that FinCEN should allow at least 24 months implementation deadline from the time it announces the final rule.