ICBA Comment Letter on Suspicious Activity Report Renewal Without Change

ICBA appreciates the opportunity to respond to the Financial Crimes Enforcement Network’s request for comment on the proposed renewal, without change, of currently approved information collections relating to suspicious activity reports.

Under Bank Secrecy Act regulations, financial institutions are required to report suspicious transactions using FinCEN Report 111 (the suspicious activity report or SAR).

Although no changes are proposed to the information collections themselves, ICBA believes FinCEN’s burden estimate of 1.98 hours per SAR is grossly undervalued.