I'm a novice at 314-(b), so please be patient. My research hasn't been very fruitful here.

We are responding to a 314-(b) request. We're comfortable with all of the questions that are fact based. However there is one question that is opinion based. Specifically to the point, we feel that it goes beyond the safe harbor outlined in the FinCEN Fact Sheet.

I'd like to gently decline to answer the broad question and have the bank making the inquiry be more direct. Am I going to far or being too obstinate in doing that?

The question is - did the bad guy do anything suspicious and if so, what did they do? I'd much rather the question be - did you notice activity that was consistent with the bad guy kicking puppies?

Then that is exactly what you should do.

You are being vague out of necessity, so I'm not certain what your concerns are. However, it doesn't make a nickel's worth of difference whether I would agree with you or not. This is a voluntary process and each volunteer should set its own boundaries.

Thank you Ken.