I'd like to get an opinion/consensus on the cumulative amount to enter in the following scenario:
10/2014 - SAR filed for structuring totaling $15,000 (initial report checked on item 1)
05/2015 - SAR filed for structuring totaling $15,000 (initial report checked on item 1)
08/2015 - SAR filed for structuring totaling $15,000 (continuing report checked on item 1)
The guidance states, "The cumulative amount represents the total amount involved in all SARs filed on the suspicious activity, including the current BSA SAR."
Given the guidance, does "all SARs filed on the suspicious activity" represent all historical SARs filed on that customer for structuring or all SARs filed on the "continuing activity" for that customer?
For example, on the above scenario, would you enter $30,000 or $45,000 in box #28?