If I file a SAR on a noncustomer, I will not have all the information needed to file. How do I handle this?

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...

Thanks, that really helps.

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."

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.

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?

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".

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.

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.

In the past I have left the field blank via our automated software and never got one returned.

Ditto what Waterfall said.

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