CUNA Regulatory Comment Call




November 7, 2002

Changes to Suspicious Activity Report (SAR) Form

EXECUTIVE SUMMARY

QUESTIONS REGARDING THE PROPOSAL

  1. Do you believe the proposed changes to the SAR form would serve to improve the usefulness of the form to law enforcement as well as to NCUA?





    Yes ______ No ______





    Please explain why or why not.








































  2. Are there additional/other ways to enhance the quality, utility, and clarity of the information to be collected on the SAR form?





    Yes ______ No ______





    If yes, what are those additional/other ways to improve the information collection?








































  3. Are there ways to minimize the burden of the collection of information on credit unions submitting an SAR, including through the use of automated techniques or other forms of information technology? [On October 2, 2002, FinCEN initiated the PATRIOT Act Communications System (PACS). PACS will enable financial institutions that must file under the new anti-money laundering provisions of the USA PATRIOT Act to send SARs and Currency Transaction Reports (CTRs) via a highly secure Internet service. The PACS website can be found at http://pacs.treas.gov/index.jsp.]





    Yes ______ No ______





    If yes, what are those ways to minimize burden?








































  4. Other comments?








































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