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CUNA FinCEN should streamline suspicious activity reports
WASHINGTON (6/3/09)—The Credit Union National Association (CUNA) has asked the Financial Crimes Enforcement Network (FinCEN) to streamline the process by which financial institutions submit their suspicious activity reports. FinCEN and federal banmking authorities are currently planning to reissue an unchanged version of the suspicious activity report for depository institutions (SAR-DI). In a letter sent to FinCEN on Monday, CUNA responded to a call for comments by suggesting that FinCEN change SAR-DI to allow financial institutions to file only newly uncovered information in their periodical reports. Portions of the SAR-DI form that are redundant could simply be cross-referenced with an earlier filing, thus saving the financial institution from having to replicate the entire form for each new filing, CUNA suggested. CUNA also advocated allowing SAR-DI filings to follow a format similar to that of Currency Transaction Reports (CTR). Currently, financial institutions filing a CTR are allowed to attach copies of previously filed information to the new information contained on a separate form. FinCEN should also provide “additional narrative and suspect pages” in its SAR-DI forms, CUNA added. Additionally, CUNA suggested extending the repetitive filing threshold beyond the current 90 day schedule, as such a move would “lessen the burden of these filings on financial institutions.”


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