{
  "question_text": "If FinCEN's electronic filing system is unavailable when a SAR must be filed, what is the correct procedure?",
  "options": [
    "Complete FinCEN Form 111 by hand and mail it to the address on the form",
    "Wait until the FinCEN system is restored before filing",
    "Request a deadline extension from FinCEN due to the system outage",
    "File the SAR through an alternative electronic submission channel"
  ],
  "correct_answer": "Complete FinCEN Form 111 by hand and mail it to the address on the form",
  "correct_response": "Correct. Paper FinCEN Form 111 is pre-stored at each location for exactly this situation. The 30-calendar-day SAR deadline does not extend during an outage — you complete the form by hand, mail it, and log the outage dates, the form mailed, and the mailing date.",
  "incorrect_response": "When FinCEN's electronic filing system is unavailable, the correct procedure is to complete paper FinCEN Form 111 by hand using pre-stored forms at your location and mail it to the address printed on the form. The 30-calendar-day deadline does not extend during an outage. A missed deadline is a regulatory violation regardless of system status.",
  "unsure_response": null,
  "question_bank": [
    {
      "question_text": "If you are unavailable for an extended period as BSA/AML Compliance Officer, what must Rapido Facil Exchange Co. do immediately?",
      "options": [
        "Immediately suspend check cashing operations",
        "Allow a senior employee to cover BSA compliance duties on a temporary basis",
        "Reduce operations to cash-only transactions until you return",
        "Continue operating while actively recruiting a qualified replacement"
      ],
      "correct_answer": "Immediately suspend check cashing operations",
      "correct_response": "Correct. Rapido Facil Exchange Co. must immediately suspend check cashing operations if you are unavailable for an extended period. Untrained personnel cannot fulfill BSA compliance duties, and operations resume only when you return or a qualified backup is designated and trained.",
      "incorrect_response": "Rapido Facil Exchange Co. must immediately suspend check cashing operations if you are unavailable for an extended period. The Business Continuity Plan documents the suspension protocol. Continuing operations without qualified BSA oversight creates direct regulatory liability.",
      "unsure_response": null
    },
    {
      "question_text": "When must Rapido Facil Exchange Co. update vendor contingency documentation in the Business Continuity Plan?",
      "options": [
        "Whenever a vendor contract is renewed, modified, or terminated",
        "Only at the annual Business Continuity Plan review",
        "Only when a vendor system experiences an actual outage",
        "Within 30 days of any operational change at the vendor"
      ],
      "correct_answer": "Whenever a vendor contract is renewed, modified, or terminated",
      "correct_response": "Correct. Vendor contingency documentation must be updated any time a vendor contract is renewed, modified, or terminated. Outdated records mean Rapido Facil Exchange Co. may have undetected gaps in its Business Continuity Plan coverage.",
      "incorrect_response": "Vendor contingency documentation must be updated whenever a vendor contract is renewed, modified, or terminated — not just at the annual review. Waiting until the annual review to update vendor records can leave Rapido Facil Exchange Co. with undetected coverage gaps.",
      "unsure_response": null
    }
  ],
  "enrichment_content": "<p><strong>Key point:</strong> BSA filing deadlines are absolute — they do not pause for system outages. Paper forms stored at each location are the required fallback when FinCEN's electronic system is unavailable.</p><ul><li>CTR: complete FinCEN Form 112 by hand and mail it — 15-day deadline stands.</li><li>SAR: complete FinCEN Form 111 by hand and mail it — 30-calendar-day deadline stands.</li><li>Log the outage dates, each form mailed, and the mailing date every time.</li></ul>"
}