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#1897429 - 02/14/14 05:11 PM Addresses in Part III of SAR
Kelsey D Offline
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Joined: Aug 2006
Posts: 516
Ohio
Let's suppose I'm filing a SAR, and the transaction took place at one of our branches, not the main office. My interpretation of the instructions is this. In Part III, complete the top portion (47-63) with the address of our headquarters (aka main office) and complete the bottom portion (64-70) with the address of the branch where the activity occurred. Our BSA software provider filed SARs like this up until September 2013. Then they referenced FinCEN's FAQ below and changed the mapping to have the branch where the activity occurred in 47-63, with 64-70 blank, unless multiple branches were involved. Their interpretation of the FAQ is that “the depository institution location where the activity occurred” means branch location if the transaction was at a branch and not the FI headquarters. Are they interpreting this correctly?

FAQ 20

Quote:
b. A single depository institution with multiple branches files their SARs out of the home office of the depository institution. In this scenario, Part IV would be completed with the information of the home office of the depository institution, and then a Part III would be completed for the depository institution location where the activity occurred. If the activity occurred at additional branch locations of the depository institution, then that information would be entered in Items 64 – 70, and would be repeated as many times as necessary. In Part IV, the filing institution should enter the name of the contact office that should be contacted to obtain additional information about the report.
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#1897450 - 02/14/14 05:39 PM Re: Addresses in Part III of SAR Kelsey D
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
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Very good, well framed question, but the only people who could possibly answer it with assurance work for FinCEN. They are not final because they are right, they are right because they are final.

I suggest you start with the Helpline and confirm your conversation in writing, but I would have to assume your vendor already did that before it made the change.

P.S. FWIW, I agree with you. If this was a Joint Report; i.e. multiple banks were filing the same report, but all of the activity was at the branch level, your vendor would be listing each individual branch in its own part III. Note also that items 62 & 63 reference a number and financial amount that apply to the bank as a whole, not to an individual branch.
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#1898756 - 02/21/14 02:16 PM Re: Addresses in Part III of SAR Kelsey D
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
I spoke to FinCEN, and their response is that the branch address should not go in the top portion of Part III. 47-63 is asking for information about the financial institution headquarters. 64-70 is where the branch information and address would be listed if a branch was involved. We were instructed to amend the SARs that were filed incorrectly. We're still working with our vendor to get them to agree with us on how to flood the information into the SAR. They are revisiting the issue. The only guidance they had to refer to was that FAQ, so I have a feeling they will be speaking with FinCEN about it for more clarification. I hope that they get the same answer that I did.
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Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

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