At the ABA MLEC in Washington last month Michael Delucca from FinCEN indicated that the revised SAR should be published on December 4 and should be ready for use in February, 2007. Its use will be mandatory by August 1, 2007. In addition to a revised format, the form will include more detailed instructions and allow for "joint" filings by depositary institutions filing on the same fact situation.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.