Good morning!

Ya'll! I'm thinking way too hard about this one.

SAR field #27 FI TIN and account number(s) affected that are related to Subject

I'm filing a SAR for counterfeit checks. I'm using the payee names of the checks as the subjects. They are not our customers. I leave field #27 as no known accounts involved, right?


Thanks!

There is no account number listed on the counterfeit checks?

The account number on the check belongs to our customer, who isn't the subject. There is not an account number listed on the endorsement on the back of the checks.

You still include the account number of the counterfeit checks. It's related to the subject in that the subject had possession of the check and negotiated it. "Related to" does not equate to "Owner/"

An account is related to a subject if the subject owns the account, has control over the account, or conducted activity in or through an account the subject does not own or control.

Thank you both.