WASHINGTON – In a letter last week to NCUA, CUNA asked for more guidance in filling out Suspicious Activity Reports.
CUNA's letter was in response to proposed revisions to the SAR form that have been submitted by the Financial Crimes Enforcement Network and the regulators to the Office of Management and Budget for approval.
CUNA generally supported the draft SAR revisions aimed at improving the form, but strongly urged the regulators to publish additional guidance on when to file a SAR to curb so-called defensive SAR filings as well as to reconsider their decision to maintain existing reporting thresholds and filing deadlines. CUNA asked that this guidance be subject to public comment before issued in final form. The regulators, according to CUNA's letter, are currently reviewing draft guidance.
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The narrative section of the form should be modified so the wording is "more orderly" and the sentence "Supporting documentation should not be filed with this report." is as prominent as possible, CUNA Senior Regulatory Counsel Catherine Orr wrote in CUNA's letter. "We also think that the block that asks for the total amount involved in the known or suspicious activity is the logical spot to indicate U.S. or foreign currency as opposed to the narrative section," she added.
CUNA also asked that "computer intrusion" be defined in the general instructions; that the phone number for the FinCEN Financial Institutions Helpline to report suspected terrorist-related activity be included in the instructions; and that the agencies reconsider the estimated time to complete a SAR again.
The planned effective date for the new SAR forms is Jan. 1, 2007, but could be adjusted for institutions to have appropriate time for compliance.
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