We have filed a SAR and are preparing an updated SAR on counterfeit/altered checks that have been presented to the bank for payment on a specific account. Currently, the amount is up to about $500,000. The problem is that the volume of checks is significant and it is an extremely long narrative to input every little detail about the checks. (Payee, bank of deposit, account numbers, address of payee, ID info) Basically, we've been including whatever information we have because it appear to be a large ring (or maybe just one guy who washed and sold the original stolen check).

I'd really like some input on how other banks are handling this sort of thing. Do you put every little detail into the narrative, or do you summarize? Seems to me we're stuck doing the details, but I'm getting some push back because it's such a time consuming process.

Any input is appreciated. Thanks!

Obviously, listing every item would be preferred. BUT, often on a ongoing filing I will list the fact that activity is still occurring and copies of all checks are being retained. I also would list any trends or changes from the original filing.

I cannot speak for law enforcement in your area, but we were told by an agent that when a SAR is too long with too many details, it does not get a lot of attention. They said a SAR should be concise and to the point. They said that a representative sampling of the transactions with a total of all transactions would be fine. We do that where there are a large number of transactions and always include in the narrative a statement to the effect that it is a representative sampling and that copies of all transactions are available in the SAR supporting documentation.

Unlike what Retread was told, we were told in a recent seminar in our state by an FBI agent to include as much detail as possible in the SAR--I think it literally might depend on which agent is reading it as to their preferences for concise or every detail...!
When I have filed this type of SAR I do try to include every item and pertinent info, however if you're talking over 30 items I would have to agree that a representative sampling with back-up copies available for law enforcement should suffice for the SAR narrative. I would include in the narrative the total number of items and the fact that copies of fraudulent items are available upon request.

I really like the idea of a representative sample. It seems like a reasonable way to go considering the volume I'm dealing with.

Thank you so much for your thoughts!

Maybe I should rephrase. We provide details of what we believe are the suspicious activities. We just do not include details of every transaction. If we did, some of our SARs would be over 40 pages long.

I recommend putting an "executive summary" up front. The law enforcement personnel I often visit with tell me to "punch" them upfront with the big picture and leave out the details. Then give them all of the nitty gritty details. If they want to read that much, it's available, but they don't have to "waste" their time to get the facts.

A good way to do this is by listing transaction ranges: "(count) counterfeit checks totaling, $xyzpdq have been presented. Individual items vary in amount from $x to $z..."

I get the same response from law enforcement. I used to word my SARs "Who, What, Where, When, Why, How" ... but have since changed the order to "What, How, Who first - the rest later"

Mind you this is for the long & lengthy detailed repetitive SARs ...

but I list in my narrative what SAR Documentation I have available & simply state that I have "Detailed individual transactions by teller, location, date, & time". If they want it - they call & ask.