BOL Friends to the rescue - - - PLEASE
I can't find any guidance from FinCEN on this & my brain is fried.
I understand there is FinCEN guidance that states Item 34 should be the Cumulative Total of all suspicious activity from the date first reported in the First SAR filed. ie 3-10-2006 to now.

Item 33 is the Dates of suspicious activity and I have always filed using this as the "Reporting Period" = the last 90 days of activity. ie 6-10-09 thru 9-10-09. This has passed prior Fed Exams, State Exams, & Indep. BSA Audits.
NOW - our independent BSA auditor is indicating this date should start with 3-10-2006.

I participated in SAR Form Completion training in 2008 with Ken Golliher and the training indicated for a recurring SAR on ongoing activity, the "from" date should be the one shown on the first SAR filed.

Auditor is correct, if you're filing a recurring SAR for the same activity, the from date should be the original date the first SAR was filed and you should be accumlating the dollar amount as well.

The SAR Activity Review Issue 8

See page 32... "The date range and dollar amounts should be cumulative, encompassing the entire period of suspicious activity (not just the last 90 days)."

THANK YOU - - THANK YOU

Yeah, what kelsey linked, I couldn't get to it first.