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#1553073 - 05/18/11 03:58 PM SAR Narrative Number of Pages
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Isn't there currently a limit to how many SAR narrative pages you can have that they are supposed to increase at some point? How many can you have now?

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#1553098 - 05/18/11 04:06 PM Re: SAR Narrative Number of Pages Compliance Lover
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If I remember correctly, you can currently have up to 99 pages. The talk is that this will be reduced to approximately 6 pages. They want a concise and descriptive story, not a novel. smile
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#1553108 - 05/18/11 04:10 PM Re: SAR Narrative Number of Pages EB, CAMS
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Ok, thanks. I thought it was the other way around.

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#1553595 - 05/19/11 12:53 PM Re: SAR Narrative Number of Pages Compliance Lover
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I spoke to an IRS criminal investigation agent on a conference call last week. He told me that SAR narratives are way too wordy and all they want is a quick summary of the activity or it loses their attention. I found this odd because we have several customers we file on who's transactions are quite complicated and without a detail day to day, I don't think anyone can fully understand the nature of the activity. This was an agent who's responsible for the entire New England region and he said the group meets once per month and has over 3,000 SARs to review so too wordy is not good.

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#1553598 - 05/19/11 01:01 PM Re: SAR Narrative Number of Pages P*Q
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Nearly all SARs I complete fill one page of narrative. Sometimes they wander into two pages. I notice that because mine are usually based on structuring or excessive cash, there's no need to be wordy. However, when reviewing SARs written by our fraud group, wordy is necessary. Sometimes, things HAVE to be explained in a way that may take a few pages. I have had to ask some folks to be sure to at least break their narrative into paragraphs, however. Many cram the entire thing into one, long, hard-to-read clump. Yikes.
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#1553602 - 05/19/11 01:08 PM Re: SAR Narrative Number of Pages Compliance Lover
Elwood P. Dowd Offline
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Frog Lady's numbers are correct. I think that "downsizing" the SAR narrative to a good story rather than a recitation of details available from supporting documentation makes good sense.

SARs are like newspapers, they have a diverse readership and their readers have never been able to articulate a common direction for their authors. Making no attempt to represent every position Iíve heard offered by FinCEN and SAR review specialists, I think you just need to tell a good story in chronological order and make certain your supporting documentation provides enough detail to prove that the story you told is correct.
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#1553609 - 05/19/11 01:19 PM Re: SAR Narrative Number of Pages Elwood P. Dowd
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"I have had to ask some folks to be sure to at least break their narrative into paragraphs, however. Many cram the entire thing into one, long, hard-to-read clump. Yikes."

You are wasting your breath. The reports that law enforcement receive from the SAR system eliminates all line breaks, extra spaces, columns, etc. It shows up as one long narrative. That is why putting anything in a columnar format is a waste of time and basically makes the information indiscernible.
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#1553617 - 05/19/11 01:32 PM Re: SAR Narrative Number of Pages rlcarey
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When speaking with law enforcement regarding some of our SARs, the copies they've had in their hands mirror what we submitted originally, formatting and all. Is this because we submit ours electronically?
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#1553625 - 05/19/11 01:42 PM Re: SAR Narrative Number of Pages BSABecky
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It is hard to sell the idea to overzealous SAR writers, but a SAR is supposed to give a brief description of the suspicious activity along with some examples. The SAR writer is not supposed to build a case for law enforcement. They are only supposed to give law enforcment enough information to convince them to open a case. If they have to read beyond a few pages to get their attention, you can usually forget any active investigation.
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#1554101 - 05/19/11 10:55 PM Re: SAR Narrative Number of Pages Retread
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I think the problem has been Examiners from the Regulatory agencies have loved, loved, loved writing up SARS for not having an adequate narrative.

The problem became one of mission creep where the original criticism of a truly inadequate narrative became a race to the bottom where examiners were finding all sorts of nuanced details that were not fully detailed in the SAR narrative and they went to town.

I have never heard of a bank being criticized because their SARs were too verbose, so BSA/Compliance Officers will err on the side of caution because they are writing for their examiners and not law enforcement.

Would be nice if FinCEN could reach a middle ground with the regulatory agencies and MAKE IT STICK with individual examiners.
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#1554130 - 05/20/11 01:29 AM Re: SAR Narrative Number of Pages Princess Romeo
Kathleen O. Blanchard Offline

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It boils down to good writing skills - say it all as briefly as possible. If necessary, write it out and keep cutting it down, like editing a novel - shorten it without losing the story line.
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#1554176 - 05/20/11 12:56 PM Re: SAR Narrative Number of Pages Princess Romeo
Elwood P. Dowd Offline
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Quote:
...Examiners from the Regulatory agencies have loved, loved, loved writing up SARS for not having an adequate narrative.


I've encountered that several times. However, when the bankers pushed the point and asked for specific things that were omitted from a particular SAR the critics were never able to come up with any suggestions - nothing at all.

They would be a lot smarter if they just said "Duh, it isn't long enough."
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#1554276 - 05/20/11 02:00 PM Re: SAR Narrative Number of Pages Elwood P. Dowd
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The latest SAR Activity Review has a whole section on effective SAR narratives.

http://www.fincen.gov/news_room/rp/files/sar_tti_19.pdf
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#1554299 - 05/20/11 02:10 PM Re: SAR Narrative Number of Pages Retread
Elwood P. Dowd Offline
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Note well the length of the narrative described as "effective."
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#1554650 - 05/20/11 05:02 PM Re: SAR Narrative Number of Pages Elwood P. Dowd
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Call me crazy, but I try to make all audiences happy with my SAR. Law enforcement investigators seem to want you to get to the point. Law enforcement analysts seem to want every last detail so they can interface your narrative with i2 Analyst or other data mining/mapping software. I try to achieve both with the an abstract, intro, body, conclusion format. It seems to work.
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#1554764 - 05/20/11 06:19 PM Re: SAR Narrative Number of Pages Pat Patriot Act
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Law enforcement can request the supporting documents. Give them an idea as to whether they should. Call it good. I've never gone longer than 1 page. My supporting docs are very detailed, though.

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#1555097 - 05/20/11 10:12 PM Re: SAR Narrative Number of Pages Pup
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I guess my point was that FinCEN needs to place some blame on the examiners with the regulatory agencies for the word bloat in SARS. If examiners had provided better guidance instead of trying to hang another scalp on their belt, maybe we wouldn't have BSA Officers more concerned with cramming the kitchen sink into the SAR out of fear of a Cease and Desist.
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