WASHINGTON — In its latest SAR Activity Review–Trends, Tips,& Issues, the Financial Crimes Enforcement Network foundinconsistencies among shared branch suspicious activity reportfilings.

“The number of filer-name and [Federal Employer IdentificationNumbers] in BSA filing related to these cooperatives couldcomplicate future efforts to correctly identify and aggregate SARfilings involving the cooperatives and their affiliated entities.Data consistency problems and other data-quality issues prolongedand hindered efforts to collect and evaluate data for thisanalysis,” the report read. In many cases, FinCEN found, the filinginstitution already has the correct information on hand.

NAFCU Director of Compliance Anthony Demangone said the reportdoes not necessarily mean this will be a new area of focus forFinCEN but it raises a “red flag” for him. “If I'm in a sharedbranch, that's going to be on my to do list,” he commented.

Financial Services Center Cooperative, Inc. Executive VicePresident/Chief Operating Officer Bonnie Kramer explained that herorganization requires training for new credit unions as they signup. They also offer follow up training that is highly recommended.FSCC's policy on BSA filings outlines the necessary reports to befiled and states that they must be filed with FinCEN in a timelymanner, she said.