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#1431627 - 08/19/10 06:57 PM SAR Filing
lesterpester Offline
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lesterpester
Joined: Apr 2010
Posts: 79
The Great State of Texas
When filing a SAR for ongoing/continuous activity, the amount involved, is it the total of all cash transactions processed during the reported time frame or just the total dollar amount of trancactions that appear to be suspicious? My thinking is that the amount should be for only the suspicious activity and not a total of all the transactions conducted during the previous 90 days. I'm getting two different answers. Any suggestions? Thanks for your help!

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#1431732 - 08/19/10 07:53 PM Re: SAR Filing lesterpester
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
From the SAR preparation guidelines:

Item 34 - Dollar amount involved - Enter the dollar amount involved in the suspicious activity. If less than a full dollar is involved, round it to the next highest dollar.

It's not the gross amount of all activity, it is only the amount of the suspcicious activity. There may or may not be cash involved.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#1431733 - 08/19/10 07:54 PM Re: SAR Filing Elwood P. Dowd
lesterpester Offline
Member
lesterpester
Joined: Apr 2010
Posts: 79
The Great State of Texas
Thanks for your help, Ken. It is much appreciated!

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#1432554 - 08/21/10 05:49 PM Re: SAR Filing lesterpester
Pat Patriot Act Offline
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Pat Patriot Act
Joined: Apr 2009
Posts: 450
If you don't already, it can also be helpful to add a line to the narrative that clearly outlines what you're using for the figure in Item 34.
_________________________
CFE, CAMS

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#1434522 - 08/26/10 02:22 PM Re: SAR Filing Pat Patriot Act
Overboard Offline
100 Club
Overboard
Joined: Aug 2007
Posts: 192
Minnesota
We just had a compliance exam and we were told that the $ amount is continuous. For instance when you are filing on someone every 90 days the date on the SAR always goes back to the first one filed and the $ amount is added to the previous ones. It is not just the information for this 90 days it is accumulative.
Is this right?

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#1434541 - 08/26/10 02:39 PM Re: SAR Filing Overboard
Georgia Plum
Unregistered

That is how I've always done it and what I've also been told from examiners. It is a cumulative total from original date of the suspicious transactions.

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#1434549 - 08/26/10 02:55 PM Re: SAR Filing
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Two different concepts discussed here.

You report the dollar amount that is considered suspicious and you report that figure cumulatively in ongoing SARs.

If there is a break in SARs, you start over for the $ amount being reported and mention the prior info in the narrative. This is discussed in FINCEN guidance.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1434563 - 08/26/10 03:08 PM Re: SAR Filing Kathleen O. Blanchard
Overboard Offline
100 Club
Overboard
Joined: Aug 2007
Posts: 192
Minnesota
Thank you

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