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#2014137 - 05/14/15 06:20 PM Continuous SAR Filing Question
BruwinLady Offline
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Joined: Feb 2013
Posts: 24
Would appreciate help with the following -
We have already filed 3 SARs on a certain customer. For the following 90 day review period, a review was performed but we didn't feel a SAR was warranted and we did not file and except documented our support for not filing the SAR.

Now, the current 90 day review is due once again and the suspicious activity on the account has started again. Since we've already reported three SARs, then had a gap, and now we will reporting a SAR again, I have a couple questions on completing the SAR form as follows:
1)Will this SAR filing be considered a continuing activity Report or will it be an Initial Report?
2)Do we report just the suspicious items in the current period or do we aggregate the previously reported suspicious activity and the current period suspicious activity in the Cumulative Amount field?

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#2014139 - 05/14/15 06:32 PM Re: Continuous SAR Filing Question BruwinLady
CrashDavis Offline
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Joined: Jun 2005
Posts: 283
I have had situations like this and I have treated the as an initial report. I do place in the narrative that I had filed SARs previously and give the date and the DCN Number.

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#2014178 - 05/14/15 07:43 PM Re: Continuous SAR Filing Question BruwinLady
BruwinLady Offline
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Joined: Feb 2013
Posts: 24
Thanks Crash! I thought this was the case but was hoping there was guidance or FAQ or something else on the topic.

By the way.. Bull Durham is one of my fave movies.

"I believe in the church of baseball....

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#2014180 - 05/14/15 07:51 PM Re: Continuous SAR Filing Question BruwinLady
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
There's no official ruling, but calls to the Helpline over several years have yielded a consistent answer: If there has been a break of more than 90 days, the next SAR is not a "continuation" SAR.

Regardless it would be prudent to summarize the preceding activity at the beginning of the narrative and provide the DCN of the final chapter in the earlier series.
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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