CUNA Regulatory Comment Call


January 11, 2000

Suspicious Activity Report

(Not a Major Rule)

EXECUTIVE SUMMARY

The Financial Crimes Enforcement Network (FinCen), and the National Credit Union Administration, the Office of the Comptroller of the Currency, the Office of Thrift Supervision, the Federal Reserve Board, and the Federal Deposit Insurance Corporation (collectively, the "Agencies") have jointly issued a notice and request for comment concerning the Suspicious Activity Report (SAR). No new reporting requirements are being added.

The Agencies are submitting this request for comments again. After a request for comments was issued in September, the Agencies decided to incorporate some of the commenters suggestions and resubmit a revised proposal for comments. As before, the notice revises the SAR without making substantial additions to the content of the form. The changes include the following (the new changes are in bold):

Also, the Agencies agreed with CUNA’s comment that they should allow electronic filing of the SAR. The Agencies stated that electronic capability would be a future goal.

Comments are due by February 7, 2000. Please submit your comments to CUNA by January 31, 2000. Please feel free to fax your responses to CUNA at 202-371-8240; e-mail them to Associate General Counsel Mary Dunn at mdunn@cuna.com or to Assistant General Counsel Michelle Profit at mprofit@cuna.com or mail them to Mary or Michelle in c/o CUNA’s Regulatory Advocacy Department, 805 15th Street, NW, Suite 300, Washington, DC 20005. You may also contact us if you would like a copy of the notice, which includes a copy of the proposed form.

If you would like to access the notice on the Internet, please click here to go to the Federal Register Website. Please enter "1/07/00" as the date and type "FinCen" as your search term.

QUESTIONS TO CONSIDER REGARDING THE NOTICE ON SARs

Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
Mary Mitchell Dunn • SVP & Associate General Counsel • (202) 508-6736 • mdunn@cuna.com
Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 • jbloch@cuna.com
Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 • corr@cuna.com