CUNA Regulatory Comment Call


July 5, 2006

Suspicious Activity Report (SAR) Form Revisions

EXECUTIVE SUMMARY

DESCRIPTION OF THE PROPOSED SAR REVISIONS

QUESTIONS REGARDING THE PROPOSED SAR REVISIONS

  1. Do you agree with the proposed effective date of January 1, 2007?

    Yes ______ No ______

    If no, why not? What effective date would be more reasonable?
















  2. Does the change to proposed check box 1a to indicate “recurring” report instead of “updated” report and accompanying instructions explaining this box should be checked for a “recurring report filed on continuing activity” make sufficiently clear what the box is intended to encompass?

    Yes ______ No ______

    If no, what additional clarification is needed?
















  3. One important change in the new form is removing the name of the financial institution contact from the form. Do you agree with this change?

    Yes ______ No ______

    If no, why not?
















  4. Do you think box 42 (Relationship of the subject (Part 1) to the above listed financial institution) and corresponding instructions are sufficiently clear in the case of multiple subjects?

    Yes ______ No ______

    If no, how could those instructions be further clarified?
















  5. Do you agree with the addition in Part I of a box for the filer to indicate the subject’s e-mail address?

    Yes ______ No ______

    Please explain.
















  6. Are there other ways in which the SAR form could be simplified, shortened or clarified?

    Yes ______ No ______

    If yes, what are your suggestions?
















  7. Other comments?
















Eric Richard • General Counsel • (202) 508-6742 • erichard@cuna.com
Mary Mitchell Dunn • SVP & Deputy General Counsel • (202) 508-6736 • mdunn@cuna.com
Jeffrey Bloch • Assistant General Counsel • (202) 508-6732 • jbloch@cuna.com
Lilly Thomas • Assistant General Counsel • (202) 508-6733 • lthomas@cuna.com
Catherine Orr • Senior Regulatory Counsel • (202) 508-6743 • corr@cuna.com