Hello all, I have an audit examination recommendation that has me a bit stumped. It was our independent audit FYI.

The auditor wrote "It was noted during the review that the Bank was completing the top portion in Part III of the SAR with the information from the Main Branch when the suspicious activity did not occur. It is recommended that the Bank only include the information from the branches where the suspicious activity occurred in Part III of the SAR."

When I questioned the auditor on this he said that he and his team had been on the phone with FDIC regulators many times on this issue and this was the FDIC's final decision on this topic. My BSA software doesn't allow for the top portion of Part III on the SAR form to have any other information then our main branch information. The bottom of Part III is where we list the branch where the suspicious activity occurred.

Has anyone else had this finding form their audit? I went back to my BSA software provider and they were not familiar with regulators requesting this change.

Thanks in advance!

The software I use (Verafin) has Part III as the financial institution where it occurred and a separate section for the branch. I have not heard anything else otherwise either.

While I use a different program than BSA Gal, mine works the same and has the Banks information at the top and the branch where activity occurred information on the bottom.

Part III Information about Financial Institution Where Activity Occurred ------------

Part III records information about the financial institution(s) where the suspicious activity occurred. Complete a
separate Part III record on each financial institution involved in the suspicious activity. If box 1d “Joint report” is
checked there must be two or more Part III records in the FinCEN SAR, one for the Part IV filing institution or filer
subsidiary and one for each joint filer.

If a financial institution recorded in Part III has branches involved in the suspicious activity, record the branch information in Items 68 through 74. Information for up to 99 branches can be recorded in a single FinCEN SAR. A branch is a location (such as an office or ATM) owned by the financial institution but located separately from the financial institution’s headquarters.

Thanks guys for your input. This was my first BSA Audit as BSA Officer so I questioned it and researched it but he wasn't backing down. Not sure what to do from here. I have to report this to my board and it seems silly!

Send an email to the FinCEN help desk to see who they agree with. If they agree with the auditor, it is what it is. If they agree with you, then put that in your Management response and say, "Thanks for the recommendation, but we are going to leave things as they are."

Ok I will try that, thank you Brian C