We do a 90 day review of activity to determine if a continuation should be filed. We have a case where we filed a SAR close to a year ago. Then nothing; now the activity has started up.
We don't believe that the SAR which we will file is a continuation of the other SAR due to the break in time, however, has the Feds ever opined on this? We are seeing lots of opinions and procedures that are all over the place as to continuations.
Comments welcome.