BEGINS RANT:
FinCEN really needs to focus on maintaining a consistent message on the details of how things should be done. Without getting into specifics, there are plenty of topics among the forms, instructions, and FAQs where they seem to contradict themselves or have misleading information.
Some of my favorites include:
The FAQ instructing users to include in Part III, under the heading "Financial Institution Where Activity Occurred" the branch of suspicious activity if it's not the home office and it's the only branch involved, while having the "Branch where activity occurred information" then require the user to check off "If no branch activity involved, check this box" to not have to enter in the same branch twice.
The form Item 27 being labeled "Date or date range of suspicious activity for this report" while indicating in the instructions "If "Continuing activity report" is selected as the filing type, enter only the date range covered by this SAR", which some examiners are reportedly interpreting as meaning Item 27 on a CAR equals the "period reviewed" while others interpret as Item 27 on a CAR equaling the date range of suspicious activity within the date range of the review of the CAR.
The whole "90-Day Review" debacle. First we file every 90 days, then every 120, then every 90 again, then every 120 - but it can only be on 90 days worth of activity (better not be 91!!!). This is is well documented, so I won't go any further...
Then one person says a FinCEN Rep. said this, while another said FinCEN Rep. said that. And as always, both FinCEN reps refused to put it in writing.
END RANT
I'm sure there are more examples...
Moderators: Perhaps a "sticky" thread is needed to document all of the "inconsistencies."
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CFE, CAMS