"It is no great insight to conclude that the conception of a single, clear policy
on suspicious activity reporting combined with consistency in the application
of that policy is the solution to the defensive filing phenomenon. Yet such
consistency continues to be elusive. Together with our partners in the federal
regulatory agencies and law enforcement, we are working to ensure clear,
unified Bank Secrecy Act policy that all stakeholder agencies apply consistently...."
"....I reaffirm my pledge to continue to work closely with the
industry and all others to ensure the consistent application of the suspicious
activity reporting regulation."
--William J. Fox, Director, FINCen, in SAR Review Issue 8
We can only hope.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8