Ken provided a link above to a discussion regarding how to calculate. Much depends on your procedures so make sure you are consistent in your application of the calculation. There is no guidance on how far back you go. if your program dictates a time period, use that as a starting point. If it is determined that the activity started before, feel free to go back and get it all. Be prepared to explain to regulators any situations where the activity went on for an extended period of time without being identified. Document any new systems, reviews or processes that may have identified the activity at this point and prompted the review going back.
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CAMS, AMLP, AKC, K-9