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Returned Item & Date Reported On SAR

Answered by: 
Randy Carey
John Burnett

Question: 
My question is in regards to a returned item and the date that should be reported on the SAR. We were recently advised that the suspicious date for the returned item should be the date of the original deposit and not the date it was returned. But isn't the item being returned the suspicious nature of the transaction so shouldn't we use the returned date instead?
Answer: 

by Randy Carey:

Does it really make much difference? Law enforcement is not going to care.

Answer: 

by John Burnett:

There is an argument that the "crime," if there is one, took place when the check was issued, at the time it was deposited, or at the time the check was dishonored. Frankly, I agree with Randy -- it is a distinction without a difference. I don't wish on you a lot of this sort of suspect activity, but I'd pick a date to use and try to be consistent.

First published on 12/09/2018

Filed under: 
Compliance
Filed under compliance as: 
Suspicious Activity
SAR

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