Playing around with the new BSA SAR poses lots of questions, but today I'm curious about item #25 Subject's role in suspicious activity (if applicable)
a. Purchaser/Sender
b. Payee/Receiver
c. Both

How is this being interpreted? Say for example, customer structures several cash deposits... what would his role be? I notice that it is not a required field, so would it be considered not applicable?
Curious to hear how others interpret this?

Keep in mind, Form 111 is a "multi-industry" form; i.e. it has lots of choices and language that have nothing to do with depository institutions.

I called the Helpline with the same question. I was told that it applied to the brokerage industry and that filers of the form were not obligated to fill out portions of it that did not apply to them.

Since it was the answer I wanted, I accepted it...

Thanks Ken, I find a lot on Form 111 to be either redundant or initially confusing. Is it really necessary for the bank's EIN and identification information to be entered so many times? It took me all day to figure out the RSSD number... I am sure there is a reason for all of this extra data, but really Yuck!
I guess I will either adapt or go extinct!

It did not take me that long. After I floundered around for an hour, I asked Kaybee!

When they ask for information that seems repetitive, keep in mind that the form may have multiple filers and multiple locations where the activity takes place. If there are two banks with seven branches involved they need the RSSD on each branch to know which bank it belongs to.

Ooohhhhhh, should each branch of our bank necessarily have a separate RSSD? I'm pretty sure we just have the one....

I will ask the question to save me time, what is RSSD?

Go to the NIC, which you can access via the FFIEC site. You can look up your bank's RSSD number, which is also on your call report. It has been there all along.

http://www.ffiec.gov/nicpubweb/nicweb/NicHome.aspx

It stands for Research Statistics Supervision and Discount (RSSD) number; the RSSD numbers are issued by the Board of Governors of the Federal Reserve System.

It is being used for more things now (SAFE Act, efiling, etc.) so more people outside of the finance department are becoming aware of it.

RSSD ID
The RSSD ID is a unique identifier assigned to institutions by the Federal Reserve. While the length of the RSSD ID varies by institution, it cannot exceed 10 numerical digits.

Here's the website to look your bank's up.

http://www.ffiec.gov/nicpubweb/nicweb/SearchForm.aspx

No; your bank only has one RSSD. However, if you list three branches on the SAR each listing must incorporate that RSSD.

Thanks for the info.