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#2145022 - 09/06/17 07:44 PM Repeating Information in SAR Narrative
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,211
The West
The FinCEN Suspicious Activity Report SAR Electronic Filing Instructions state on page 111 "Information provided in other sections of the FinCEN SAR need not be repeated in the narrative unless necessary to provide a clear and complete description of the suspicious activity." Further down on the same page it states, "Indicate where the suspicious activity took place, e.g. BRANCH, cage, gaming pit......"

Is it sufficient to say the suspicious activity took place at our XYZ BRANCH without providing the address in the narrative?. I'm asking because the address is already provided in Part III.

Just wondering how others are doing it.
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#2145026 - 09/06/17 07:49 PM Re: Repeating Information in SAR Narrative TryingtoComply
Daisy Doodle Offline
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Joined: Feb 2014
Posts: 1,030
Southern U.S.
We do a shortened version for the narrative. Ex: Br 1 in Bakersfield.

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#2145027 - 09/06/17 08:03 PM Re: Repeating Information in SAR Narrative TryingtoComply
Beachbum, CRCM Offline
Gold Star
Joined: Dec 2006
Posts: 499
Knee Deep in Regs
We do the same as Daisy but reference the specific part of the SAR.
Example: Branch 1 in Bakersfield (part III)
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#2145034 - 09/06/17 08:25 PM Re: Repeating Information in SAR Narrative TryingtoComply
bcompliance Offline
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Joined: Sep 2014
Posts: 1,294
we list the address - the way it was done before I got here. not my personal preference, because that is doing what the instructions say not to do. I would go with Daisy and Beachbum's method.
Last edited by bcompliance; 09/06/17 08:26 PM. Reason: spelling
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#2145042 - 09/06/17 08:55 PM Re: Repeating Information in SAR Narrative TryingtoComply
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 2,211
The West
I like Beachblum's suggestion and will implement. I'm new to the bank and beginning to notice more and more things as I'm reviewing SARs. At my previous bank examiners actually noted that we were not observing the instructions, so we were very careful not to repeat information.

Thanks everyone for sharing your thoughts!
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