Under previous management, I was instructed to file separate Marijuana Limited SARs for members of a Marijuana Business. Although my gut feeling told me no, I followed those instructions being that I am fairly new to my position (and he has been with the bank since before I was born). We recently had an internal auditor examine a few SARs. She noted that these three SARs needed to be combined. (I knew I was never wrong.) But as the 90 day filing is due, I am confused on how to go about this Marijuana Limited SAR. Here’s my gut feeling:
Filing Type: Intial
Amount Involved: Amount of all three separate SARs plus the new SAR.
In my narrative, I would include all three DCN #’s for the previous SAR filings.
Can anyone tell me if this is correct? Thank you!