Joint Comment Letter on Renewing Suspicious Activity Report Form

ICBA and the Bank Policy Institute, Financial Technology Association, American Gaming Association, and Securities Industry and Financial Markets Association welcome the opportunity to respond to FinCEN’s notice under the Paperwork Reduction Act for comment on its proposal to renew without change the suspicious activity report (FinCEN Form 111) form used by financial institutions to report suspicious transactions to FinCEN.

FinCEN’s burden estimate of 1.98 hours per SAR substantially underestimates the amount of time required to thoroughly undergo the reviews and processes required under applicable requirements to file a SAR.