SAR FAQs - What information should be provided in Items 78 – 90 in Part IV of the FinCEN SAR?

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Q:  What information should be provided in Items 78 – 90 in Part IV of the FinCEN SAR?
 
A:  Part IV records information about the lead financial institution, holding company, agency, or other entity that is filing the FinCEN SAR. Below are examples of how Part IV would be completed in various scenarios.
 
a. A Bank Holding Company (BHC) has implemented an enterprise-wide approach to their compliance program. As a result, the BHC will file all required reports with FinCEN. In this scenario, Part IV would be completed with the information of the BHC, and then a Part III would be completed with the information of the financial institution where the activity occurred. If the activity occurred at additional branch locations, then that information would be entered in Items 64 – 70, and would be repeated as many times as necessary. In Part IV, the filing institution should enter the name of the office that should be contacted to obtain additional information about the report.
 
b. A single depository institution with multiple branches files their SARs out of the home office of the depository institution. In this scenario, Part IV would be completed with the information of the home office of the depository institution, and then a Part III would be completed for the depository institution location where the activity occurred. If the activity occurred at additional branch locations of the depository institution, then that information would be entered in Items 64 – 70, and would be repeated as many times as necessary. In Part IV, the filing institution should enter the name of the contact office that should be contacted to obtain additional information about the report.
 
c. A depository institution and a money services business (MSB) decide to file a joint SAR together, agreeing that the depository institution would file the SAR. Part IV would be completed with the information of the depository institution that is filing the SAR. A Part III would be completed for the depository institution’s locations where the activity occurred. If the activity occurred at additional branch locations of the depository institution, then that information would be entered in Items 64 – 70, and would be repeated as many times as necessary.
 
In addition, a Part III would be completed for the MSB’s location where the activity occurred. If the activity occurred at additional branch locations of the MSB, then that information would be entered in Items 64 – 70, and would be repeated as many times as necessary.
 
The filing institution listed in Part IV “Filing Institution Contact Information” must identify in Part V “Suspicious Activity Information – Narrative” which of the Part III “Financial Institution Where Activity Occurred” institutions are the joint filers. The filing institution must include joint filer contact information in Part V, along with a description of the information provided by each joint filer. In Part IV, the filing institution should enter the name of the office that should be contacted to obtain additional information about the report. If a joint SAR is being prepared, please refer to General Instruction 5 “Joint Report  ” for additional instructions.
 
Please note that a branch is a location (such as an office or ATM) owned by the financial institution but located separately from the financial institution’s headquarters. If a reporting financial institution has agents where the suspicious activity occurred, a separate Part III must be prepared on each agent. An agent is an independent financial institution (such as a supermarket that sells money orders or an independent insurance agent) that has a contractual relationship with the reporting financial institution to conduct financial transactions. Do not place agent information in branch fields.
 
 
ADDITIONAL INFORMATION:
This FAQ was obtained from FinCEN’s website, FinCEN SAR FAQs section, which may be found here: 
 

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