VIDEO: Correcting a SAR without the Prior BSA ID
In this Compliance Clip (video), Adam discusses how to correct or amend a prior SAR filing through the BSA E-Filing system without a prior BSA ID. This short but sweet Compliance Clip is especially useful to those in-charge of filing FinCEN SARs.
Video Transcript
The following is a transcript of this video.
This Compliance Clip is going to talk about correcting a prior SAR filing through the BSA E-Filing system without a prior BSA ID. The question we have here is this, ”How do I correct or amend a prior SAR filing via the BSA E-Filing system if I do not have the prior BSA ID?” So you filed a SAR, but you don't have the prior BSA ID. Now you're going to correct the SAR filing, what would you do?
The answer to this actually comes from FinCEN SAR Frequently Asked Question number seven. We’re looking at the frequently asked question number seven. What it says here is “If the previous BSA ID is not known, filers should enter all zeros, 14 in total, for the previous BSA ID. The filer should complete the FinCEN SAR in its entirety, including the corrected/amended information and note those corrections at the beginning of the narrative.” So in your narrative, in the very beginning, you need to explain what has been changed and what has been corrected on the SAR filing. Then you should save it, and if desired, print it, and then provide a copy of the filing and submit the filing.
The corrected/amended FinCEN SAR filing will be assigned a new BSA ID that will be sent to the filer in the FinCEN SAR acknowledgement. The new BSA ID we'll begin with the number 31. That's how, you know it has been resubmitted or corrected. This information was actually also published in a Notice on October 31st of 2011, and the Notice is applicable to corrections and amendments for any previous SAR filing.
So what do you do when you don't have a prior BSA ID? Well, you enter all zeros, 14 in total, and then you note the changes in the beginning of the narrative. That's what you're supposed to do.
That's all I have for you for this Compliance Clip.