Ok, I know this is a basic stupid question, but I'm asking anyway. I've always done my continuing SAR filings using item 27 "date range" with the dates of the review period, my 90 days. So if I filed an initial SAR on 11/3/14 a SAR with activity ending 10/31/14, I'd file my next SAR item 27 date range with a full 90 days so 11/1/14 - 1/29/2015 (90 days), even if the activity only happened on a few days during that timeframe, my date range was always 90 days. I'm questioning my reasoning but I'm not clear even after re-reading the instructions.

* 27. Date or date range of suspicious activity for this report
a. From: mm/dd/yyyy
b. To: mm/dd/yyyy
Item *27 Date or date range of suspicious activity for this report: Enter the suspicious activity date or date range for this report. If the suspicious activity occurred on a single day, enter that date in field 27a "From" and leave field 27b "To" blank. If the suspicious activity occurred on multiple days, enter the earliest date of suspicious activity in field 27a and the most-recent date of suspicious activity in field 27b. If the exact date(s) of the suspicious activity is (are) unknown, enter a date range that the filer believes will encompass the date(s) of the suspicious activity. Explain the nature of this date range in Part V. If the FinCEN SAR involves continuing activity with box 1c "Continuing activity report" checked, enter only the date range covered by this FinCEN SAR. Record in Part V the aggregated date range of all FinCEN SARs filed on the continuing suspicious activity. Use the format MM/DD/CCYY for dates in a discrete FinCEN SAR and the format MMDDCCYY for dates in a batch-filed FinCEN SAR.

The underlined part is throwing me off though. Is it wrong to enter a full 90 days in that range? Should I only be listing the range that the actual transactions took place, possibly only 1 time in that 90 day review period? I've never been critcized for putting the full 90 day range there, but I'm questioning myself now that I'm working for an OCC bank, I'm questioning everything I know.

Any thoughts?

I always indicate the dates that the actual activity occurred.

First SAR covered activity through 10/31/2014.
My customer structured (for example) on 11/05/2014 & 11/06/2014 and didn't structure again.

The date of my continued activity would be from 11/05/2014 through 11/06/2014 (even though I didn't file my next SAR until Feb. 2, 2015.

I personally do not include the "review period" as the dates of the continuing activity.

You need to follow the instructions and enter the "date range covered by this FinCEN SAR". In It's OK's example, the review period was 11/01/14 through the end of the review period, i.e., 01/15/15. That is the period covered by the current SAR regardless of when any additional activity occurred in the period. It is not just 11/05/14 thru 11/06/14.

Thank you Randy! I thought I was loosing my mind. I've always done it as you explained above, but I'm at a new institution and they've been only listing the actual dates of the activity not the date range covered. I started doubting myself, so I spoke with a couple of BSA Officers about this and I was the only one that put the full 90 date range, so I thought I had been doing this wrong for the past 9 years and just never been "caught" in an audit or exam.

Thanks again Randy.

I agree with Its OK. Field #27 asks for the date or range of dates for the suspicious activity, not the dates of the review period. FinCEN further supports this by indicating if the activity occurred on just one date, you will leave the "to" field blank.

OK - Let's try this again.

"If the FinCEN SAR involves continuing activity with box 1c "Continuing activity report" checked, enter only the date range covered by this FinCEN SAR. Record in Part V the aggregated date range of all FinCEN SARs filed on the continuing suspicious activity."

What part of "the date range covered by this FinCEN SAR" are we missing here?

These instruction are not the same as for an initial SAR which states: " If the suspicious activity occurred on multiple days, enter the earliest date of suspicious activity in field 27a and the most-recent date of suspicious activity in field 27b."

If ItNeverEnds and I are wrong, then someone needs to explain it to me and how these instructions can be interpreted in any other manner.

And don't use the excuse that your automated AML software defaults to this position when you choose the transactions to include in the SAR.

I report the dates of activity like Its Ok and Cape Codder.

FinCEN's recorded webinar (starting at about 23:50) discussed this section of the SAR and has a visual example.

I interpret "enter only the date range covered by this FinCEN SAR" to mean don't include the date or dates reported in the initial SAR. I take it to mean they want to know what date or dates correspond to the amount you are reporting in #26.

http://treas.yorkcast.com/webcast/Play/2f93fd0fe8344ca98fe6b45c9ac312191d

I listened to the webinar linked above and it sounded to me like they were just speaking to the initial SAR when they got to item 27 - yes, in item 26 they spoke to both initial and continuing, but item 27 didn't distinquish.

You file the date range of suspicious activity within the period of the report.

If anyone doubts this, see FinCEN's example on how to handle these dates on page 28 of SAR Activity Review Issue 22.

Also, Item 27 instructions on Page 20 more clearly indicate the fields are just for suspicious activity ranges.

Lastly, the "only the date range covered by this SAR" sentence follows the following sentences:

Item *27 Date or date range of suspicious activity for this report:

Enter the suspicious activity date or date range for this report. If the suspicious activity occurred on a single day, enter that date in field 27a "From" and leave field 27b "To" blank. If the suspicious activity occurred on multiple days, enter the earliest date of suspicious activity in field 27a and the most-recent date of suspicious activity in field 27b. If the exact date(s) of the suspicious activity is (are) unknown, enter a date range that the filer believes will encompass the date(s) of the suspicious activity. Explain the nature of this date range in Part V.

When you read the "only the date range covered..." sentence, read it within the context of the paragraph it is in. As a whole, it indicates Item 27 is always the date range of suspicious activity in the report. In my opinion, they included this sentence to clarify that the new SAR form differs from the past SAR form which required the aggregate date range of suspicious activity.

I agree that this is not abundantly clear, but to me, more signs point to Item 27 being only the suspicious activity range for a continuing activity report.

PATS is correct

We do the same as Patsfan. We include the full review period dates in the narrative, only suspicious activity dates for item 27.

I agree with Patsfan, and this was confirmed as the correct procedure during our last FDIC BSA exam.

OK - I give, Uncle (taps out)

I've never been criticized in the past 8 FDIC exams for doing it the way I described. Of course I know that doesn't mean anything because it depends on the examiner, but I would have thought sometime during one of these exams (and I was at a de novo so everything was scrutinized and we were on a 12 month exam cycle for 7 years) an examiner or auditor would have made a comment. If you read the instructions, to me they seem clear, it's the review period, but apparently there's another way to interpret this as Randy & I seem to be in the minority.

Thanks for everyone's feedback. Just goes to show that there aways seems to be something new to find or learn.

This confusion has only existed since 2012, when the new form was introduced. Prior to that, the date range for continuing SARs was the start date of suspicious activity from the first SAR and the last date of suspicious activity in the continuing activity being reported.

I'm guessing that the examiners probably didn't test your dates too heavily because it's not really conducive to a risk-based approach. If you had a strong program, they probably leveraged your audit reports for catching SAR technical violations. Conversely, if you had a weak program, they would probably cite you for using the wrong dates.