Posted By: Kelsey D
Addresses in Part III of SAR - 02/14/14 05:11 PM
Let's suppose I'm filing a SAR, and the transaction took place at one of our branches, not the main office. My interpretation of the instructions is this. In Part III, complete the top portion (47-63) with the address of our headquarters (aka main office) and complete the bottom portion (64-70) with the address of the branch where the activity occurred. Our BSA software provider filed SARs like this up until September 2013. Then they referenced FinCEN's FAQ below and changed the mapping to have the branch where the activity occurred in 47-63, with 64-70 blank, unless multiple branches were involved. Their interpretation of the FAQ is that “the depository institution location where the activity occurred” means branch location if the transaction was at a branch and not the FI headquarters. Are they interpreting this correctly?
FAQ 20
FAQ 20
Quote:
b. A single depository institution with multiple branches files their SARs out of the home office of the depository institution. In this scenario, Part IV would be completed with the information of the home office of the depository institution, and then a Part III would be completed for the depository institution location where the activity occurred. If the activity occurred at additional branch locations of the depository institution, then that information would be entered in Items 64 – 70, and would be repeated as many times as necessary. In Part IV, the filing institution should enter the name of the contact office that should be contacted to obtain additional information about the report.