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CUNA Regulatory Comment Call

January 11, 2000

Suspicious Activity Report

EXECUTIVE SUMMARY

The Financial Crimes Enforcement Network (FinCen), and the National Credit Union Administration, the Office of the Comptroller of the Currency, the Office of Thrift Supervision, the Federal Reserve Board, and the Federal Deposit Insurance Corporation (collectively, the "Agencies") have jointly issued a notice and request for comment concerning the Suspicious Activity Report (SAR). No new reporting requirements are being added.

The Agencies are submitting this request for comments again. After a request for comments was issued in September, the Agencies decided to incorporate some of the commenters suggestions and resubmit a revised proposal for comments. As before, the notice revises the SAR without making substantial additions to the content of the form. The changes include the following (the new changes are in bold):

• add directions for listing multiple branches on the form if an activity occurs in multiple locations;



• modify item 28 so that the identifying number and issuing authority are requested next to each form of identification in 28(a)-(d) instead of separately;



• move the request for confession information from near the insider-related information section to indicate that confession information is wanted for all suspects;



• delete Part IV of the form altogether, including witness information (the institution contact is expected to have information regarding the preparer and witnesses);



• allow the filer to list a range of dates instead of just one date for when the activity occurred (a suggestion recommended by CUNA);



• conform all date items to a four-digit year;



• make ministerial changes, such as renumbering, clarifications, and changes to improve usefulness;



• add blocks to a number of items to allow filers to submit longer information including, 9-digit Zip Codes and larger dollar amounts;



• delete items, including questions regarding the size of the institution and the birth date of witnesses, as well as witness and preparer information;



• replace the question asking for the address of the law enforcement agency with a question asking for the name and telephone number of the person contacted at the law enforcement agency;



• clarify the question concerning the type of report prepared by eliminating "Supplemental Report" so that the question will now ask whether the report being filed is an "Initial Report" or an " Amended Report;" and



• revise the question summarizing the activity by adding a box labeled "Computer Intrusion" and defining a "Computer Intrusion."

Also, the Agencies agreed with CUNA’s comment that they should allow electronic filing of the SAR. The Agencies stated that electronic capability would be a future goal.

Comments are due by February 7, 2000. Please submit your comments to CUNA by January 31, 2000. Please feel free to fax your responses to CUNA at 202-371-8240; e-mail them to Associate General Counsel Mary Dunn at mdunn@cuna.com or to Assistant General Counsel Michelle Profit at mprofit@cuna.com or mail them to Mary or Michelle in c/o CUNA’s Regulatory Advocacy Department, 805 15th Street, NW, Suite 300, Washington, DC 20005. You may also contact us if you would like a copy of the notice, which includes a copy of the proposed form.

If you would like to access the notice on the Internet, please click here to go to the Federal Register Website. Please enter "1/07/00" as the date and type "FinCen" as your search term.

QUESTIONS TO CONSIDER REGARDING THE NOTICE ON SARs

• Do you agree that the new changes described in the notice will improve the SAR reporting requirements? Please explain.




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• Do you believe that all of the information requested on the SAR is necessary? Are there any questions that could be deleted other than the ones described in the notice?




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• Do you have other suggestions for changes that would improve the quality, clarity, or usefulness of the information that is collected on the SAR?




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• What costs do you incur in order to provide the information requested on the SAR?




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• Other comments?




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