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Washington
iCompliance Challengei covers SAR reporting
WASHINGTON (11/29/10)--The Credit Union National Association (CUNA) has advised that credit union employees completing supplemental suspicious activity report (SAR) forms may provide a range of dates that a suspected activity has taken place, rather than simply providing the most recent time that a suspicious activity may have happened. According to FinCEN’s instructions, employees should complete the supplemental SAR form and provide a range of dates of suspicious activity that capture activity from the beginning date, as documented on the initial SAR report, up to the most recent occurrence. The dollar amount of the potentially criminal activity should be provided in the aggregate, and should reflect the total of all transactions and not the loss to the credit union. Previously issued SARs should also be mentioned, and the activity itself should be well documented, CUNA added in this month’s Compliance Challenge. The Compliance Challenge also noted that credit unions should retain their own copies of filed SARs and any supporting documentation for a period of five years following the initial SAR filing. FinCEN is unable to verify receipt of previously filed SARs or provide a copy of a previously filed SAR to institutions, the Compliance Challenge notes. For the full Compliance Challenge, use the resource link.


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