Question: In Volume XIV, Number 3, you had an answer suggesting that we file a Suspicious Activity Report when we have an identity theft instance, or a fraud loss, even though our loss is under $5,000. We talked it over, and we respectfully disagree with your answer. If we filed every time we have a case like this, we'd have to put someone on writing up SARs all the time.
Answer: In the answer I said "... the confusion on the filing of a SAR may be because it says you MUST file if the loss is over $5,000. However, communication from FinCEN is that you MAY file, even if there is no loss whatsoever. So feel comfortable in filing, even if your loss is less than $5,000." Further conversation with FinCEN revealed that they would be OK with the fact that you pick and choose. Every loss may not be worth filing on, but there may be some that are under $5,000 that have significant or unusual facts that could be of some value in an investigation. Doing some does not mean that you have to do all.
And you may disagree with me any time you choose to!
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