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#1643646 - 12/28/11 02:59 PM SAR with suspect a noncustomer
Compliance101 Offline
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Compliance101
Joined: Oct 2004
Posts: 473
Tennessee
If I file a SAR on a noncustomer, I will not have all the information needed to file. How do I handle this?
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#1643740 - 12/28/11 04:24 PM Re: SAR with suspect a noncustomer Compliance101
Banker Chick Offline
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Joined: Jul 2006
Posts: 37
TN
In Part II, you will list what is known (even if incomplete). If you do not have any suspect information, you will check the suspect information unavailable box in Part II.

Hope this helps...
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#1643799 - 12/28/11 05:22 PM Re: SAR with suspect a noncustomer Compliance101
Compliance101 Offline
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Compliance101
Joined: Oct 2004
Posts: 473
Tennessee
Thanks, that really helps.
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#1644306 - 12/29/11 06:23 PM Re: SAR with suspect a noncustomer Compliance101
WonderWoman Offline
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Joined: Mar 2007
Posts: 2,108
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The SAR Trends, Tips, & Issues Volume 6, page 50 states:

"There are valid reasons why some of this data could be missing. FinCEN requests that you review your SAR reporting program and make enhancements if required. If the data (name, address, or SSN) is not available or is unknown, please indicate “not available” or “unknown” in the data box requesting the information. This is an excellent opportunity for your back office reviewers to improve your SAR reporting program."
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#1644307 - 12/29/11 06:23 PM Re: SAR with suspect a noncustomer Compliance101
WonderWoman Offline
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WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
Page 51:

What constitutes “completing” a SAR?

A SAR form has been completed when all of the available information has been entered and responses such as “none” or “not available” have been entered in any blank critical field. These responses are words, phrases, or codes that inform FinCEN that data for that item is unavailable or not applicable, and has not been simply overlooked by the filer.
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#1778478 - 01/22/13 04:33 PM Re: SAR with suspect a noncustomer Compliance101
*W*W* Offline
Platinum Poster
Joined: Feb 2010
Posts: 835
I have a non-customer suspect. I have address and DL informtion but no SSN. I tried putting XXX-XX-XXXX for the SSN on the legacy form, but I'm getting an error when I validate the form.

Suggestions? Leave the SSN blank?
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#1778570 - 01/22/13 06:48 PM Re: SAR with suspect a noncustomer Compliance101
Waterfall Offline
Member
Joined: Oct 2006
Posts: 96
PA
The reason you can't put XXX's in that field is this: (also from The SAR Trends, Tips, & Issues Volume 6, page 51) X's are only for 2 digit fields. You should be able to type in the word "Unknown".

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#1778643 - 01/22/13 08:23 PM Re: SAR with suspect a noncustomer Compliance101
*W*W* Offline
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Joined: Feb 2010
Posts: 835
Thanks Waterfall,
I tried your suggestion, but the form wouldn't accept that. I spoke to FinCen's Helpline, they suggested all 0's. That didn't work either.

I'm going to check the box "Suspect Information Unavailable" and include the information in the narrative.
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#1778716 - 01/22/13 09:50 PM Re: SAR with suspect a noncustomer Compliance101
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
I believe you can leave the field blank, as you would in a SAR for a non-resident alien, while still entering other identifying informaiton.

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#1778822 - 01/23/13 01:49 PM Re: SAR with suspect a noncustomer Compliance101
Waterfall Offline
Member
Joined: Oct 2006
Posts: 96
PA
In the past I have left the field blank via our automated software and never got one returned.

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#1779112 - 01/23/13 06:57 PM Re: SAR with suspect a noncustomer Waterfall
Cape Codder Offline
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Joined: Jul 2011
Posts: 413
Ditto what Waterfall said.
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#1779124 - 01/23/13 07:09 PM Re: SAR with suspect a noncustomer *W*W*
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Quote:
I spoke to FinCen's Helpline,


Questions relating specifically to e-filing should be asked of the Help Desk, 866.346.9478 (Option 1).
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