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#749204 - 06/07/07 09:41 PM SAR and 90 Day rule
mkp122 Offline
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Joined: Aug 2005
Posts: 219
NJ
When filing a 90 day follow up SAR I have always included the $ amount that happened during that 90 day period. At a recent conference an IRS agent said we should state the total amount from the beginning of the suspicious transaction. What is everyone else doing?

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#749207 - 06/07/07 09:47 PM Re: SAR and 90 Day rule mkp122
DebL Offline
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Joined: Jan 2007
Posts: 314
CA
Box 34 of your SAR should be the total aggregated amount, from the start of the suspicious activity to the current filing.

In the narrative we state how much of the total is current activity and how much is prior activity.

We just went through an FDIC audit and they were fine with our SARs.
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#749249 - 06/07/07 10:49 PM Re: SAR and 90 Day rule DebL
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
The aggregate total of the continuing activity from the date first detected is correct. It was addresses in one of the SAR Activity Reviews - but I can't remember which volume off the top off my head.
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#749313 - 06/08/07 10:40 AM Re: SAR and 90 Day rule rlcarey
Retread Offline
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Retread
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Southeast
MKP122,

You can find a lot of information here on SAR Filing.

http://www.fincen.gov/sarfilingquestion.pdf
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#749464 - 06/08/07 02:02 PM Re: SAR and 90 Day rule Retread
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
You can also find references to specific articles in FinCEN's SAR Review series in BOL's free SAR Research Guide. There are a number of articles there on SAR preparation, all excerpts from the FinCEN source.
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