Q: Why are the numbers on the fields in the FinCEN SAR out of order?
A: When initially published for public comment, the FinCEN SAR was structured and numbered consistent with the overall format for all the new FinCEN Reports, to include multiple Parts and beginning with the information about the persons involved in the transactions. As a result, the FinCEN SAR starts the numbering of line items on the initial “submission” page as with all the other reports, and continues the numbering in the order of Parts I, II, III, IV, and V, with some minor exceptions.
To accommodate better the dynamic nature of the report, FinCEN determined that it would be more helpful for the filing institution information in Part IV and Part III to be completed before moving to the description of the suspect and the suspicious activity. In doing so, this shifted the order of the Office of Management and Budget (OMB)-approved fields and their associated numbers within the FinCEN SAR.
While the ordering may initially be confusing, there is a significant benefit to the filer in completing Parts IV and III first. By identifying the filer’s institution type (depository institution, broker-dealer, MSB, insurance, etc.), name of the institution, the filer’s financial institution identification number (e.g., Research, Statistics, Supervision, and Discount or RSSD)/Employer Identification Number (EIN), and its address, the report enables or ‘‘auto populates’’ certain data elements elsewhere in the report. The institution can then complete the specific information on the subject(s) and nature of the suspicious activity using the data elements that have been enabled as most appropriate to its type of financial institution. In the case of a report filed jointly by two or more financial institutions, all data elements will be available for selection. Should a single filer require access to additional elements not typical for the filer’s type of financial institution, the filer can enable those other data elements for selection.
This FAQ was obtained from FinCEN’s website, FinCEN SAR FAQs section, which may be found here: