Just went to FinCEN and read the press release regarding the new SAR for FI's - how is this going to affect you? Do you see it having much of an impact on your BSA Operations?

Thanks in advance for your comments - and a great big Texas-sized Happy New Year to you all!!!!

Attended a BSA Conf earlier in the month and had some discussion...does not seem like a big deal to me

One thing to be careful of. The new SAR-DI form (FinCEN form 111) is designed to encourage joint filing of SARs. Strangely, there is no mention in the much-improved instructions section of the form that depository institutions cannot cooperate in the filing of a jointly-filed SAR unless each institution has complied with the requirements of 31 CFR 103.110 (the so-called "314b" sharing rule).

If you file a joint SAR without complying first with section 103.110, you could be liable for sharing information on a SAR filing.