Circular
New Suspicious Activity Report Form
July 11, 2000
Circular No. 11259

To All State Member Banks, Bank Holding Companies, Edge Corporations, and Branches and Agencies of Foreign Banks in the Second Federal Reserve District:

The following is from a statement by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, the Office of Thrift Supervision, and the Financial Crimes Enforcement Network:

The five federal financial institutions supervisory agencies, together with the Financial Crimes Enforcement Network (FinCEN) have issued a new Suspicious Activity Report (SAR) form.

Beginning immediately, financial institutions and organizations that are currently required to report suspicious activity pursuant to existing regulations of the federal financial institutions supervisory agencies and FinCEN may use the new SAR form to make these reports. Financial institutions and organizations may continue to use the existing SAR form while their procedures and systems are updated to make use of the new SAR form. However, only the new SAR form will be accepted after December 31, 2000.

The revisions to the SAR form reflect comments from filers and users on how to make the SAR form easier to complete and to provide more useful and timely information. In addition to modifying the layout of the SAR form for easier use, the agencies have:

Added a check box for "Computer Intrusion" to Part III, "Suspicious Activity Information," in recognition of the need to obtain more specific information with regard to computer-related suspicious activity. In addition, a specific definition of "Computer Intrusion" has been added to the "When to Make a Report" instructions at number 2.

Deleted the two sections requiring witness and preparer information and have replaced these sections with Part IV, "Contact for Assistance."

Replaced the requirements to provide the name and address of any law enforcement authorities contacted with regard to the suspicious activity being reported with Part III, "Suspicious Activity Information," items 40 through 44, to include check boxes for the law enforcement agencies contacted and to list the names and telephone numbers of law enforcement personnel contacted.

Deleted the requirement to identify whether an SAR is an "Initial Report," "Corrected Report," or "Supplemental Report." Instead, filers will only be required to identify when an SAR is being filed to correct a prior SAR. Specific instructions on filing an SAR to correct a prior report have been added in the "How to Make a Report" instructions at number 3.

Along with the issuance of the new SAR form, guidance for the preparation and filing of SAR forms has been prepared; a copy of both is enclosed. In addition, new software has been developed to assist in the preparation and filing of SAR forms. The software, as well as the new SAR form, is available at www.federalreserve.gov.

If you have any questions, please call, at this Bank, Nicholas Farco, Examining Officer, Compliance Examinations Department.