CUNA Regulatory Comment Call


October 18, 1999

Suspicious Activity Report

(Not a Major Rule)

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 referred to as the "Agencies") have jointly issued a notice and request for comment concerning the Suspicious Activity Report. The SAR is being streamlined and formatted for four-digit dates. No new reporting requirements are being added.

Comments are due by November 29, 1999. Please submit your comments to CUNA by November 22. 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 Jeffrey Bloch at jbloch@cuna.com; or mail them to Mary or Jeff 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 "9/28/99" as the date and type "FinCen" as your search term.

BRIEF BACKGROUND

In 1985, the Agencies issued procedures to be used by financial institutions to report known or suspected criminal activities to the appropriate law enforcement agencies and to the Agencies. Beginning in 1994, the FinCen and the Agencies redesigned the reporting process resulting in the existing SAR, which became effective in April 1996.

BRIEF DESCRIPTION OF THE NOTICE

The notice revises the SAR without making substantial additions to the content of the form. The changes include the following:

QUESTIONS TO CONSIDER REGARDING
THE NOTICE ON SARs

Leagues and credit unions should feel free to fax their responses to CUNA at 202-371-8240; e-mail them to Jeffrey Bloch at jbloch@cuna.com or mail them to CUNA's Regulatory Advocacy Department, Suite 300, 805 15th Street, NW, Washington, DC 20005. Thank you!!