The Federal Reserve Board has released SR letter 10-8. This letter replaces SR letter 02-24, ”Suspicious Activity Report Filing Requirements for Nonbank Subsidiaries of Bank Holding Companies and State Member Banks,” and provides clarification on compliance with suspicious activity reporting requirements of the Board.
Pursuant to Regulations H, K, and Y of the Board, state member banks, Edge and agreement corporations, U.S. offices of foreign banking organizations supervised by the Federal Reserve, and bank holding companies and their nonbank subsidiaries must file Suspicious Activity Reports on the form designated by the Board to report known or suspected violations of U.S. law.
In addition, the U.S. Department of the Treasury has issued rules under the Bank Secrecy Act imposing suspicious activity reporting requirements on a variety of financial institutions, including securities broker-dealers, money services businesses, and insurance companies.
In some instances, bank holding companies or their nonbank subsidiaries could be subject to two separate suspicious activity reporting requirements.
See SR letter for full details.