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!

Only the FinCEN helpline can tell you what is the correct way to proceed as there is no other guidance available.

Thank you!

My two cents: I would amend all three originals, pick one SAR to aggregate them in, and point the other two SARs to that one. Explain in the narrative that you disaggregated them in error, and are amending all three to comhine them into one. From that point on, you can continue filing at least every 120 days with one SAR as normal.

There's no playbook for that one, but you update each SAR accordingly and appropriately call the "sequel" a continuing SAR.