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#2177930 - 05/11/18 09:22 PM Marijuana SAR Category
MHuff Offline
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MHuff
Joined: Nov 2006
Posts: 219
LA
What category do you use to file a Marijuana Limited/Priority/Termination SAR? The guidance I've read says to use the term in the narrative, but what category should be selected for the activity? The "other" box under Money Laundering or Other Suspicious Activities??
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#2177946 - 05/14/18 09:57 AM Re: Marijuana SAR Category MHuff
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
I agree with you, check 33z and type in: marijuana [adjective]. As there is nothing official, any reviewer is going to have trouble saying that we are wrong.
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#2178042 - 05/14/18 09:06 PM Re: Marijuana SAR Category MHuff
evanruth Offline
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Joined: Sep 2015
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I work at a financial institution that banks these businesses, and the guidance we have received from our examiners has changed over our last four exams. We were initially marking 33c when we started banking these businesses in 2014. In our 2016 exam it was suggested we mark 35z and state "marijuana related business." However, we have heard from other institutions in the area that they mark it our original way, and the examiners are okay with it. Whatever you decide, just be consistent. And you must use the term in the narrative, that came up as an exception for us once.

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#2178485 - 05/17/18 12:41 PM Re: Marijuana SAR Category evanruth
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Hmmm...that's helpful. "Check all that apply."
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