On 31 May, an article from Ballard Spahr reported a Notice from FinCEN Notice that gives the financial industry and affected stakeholders an opportunity to comment on existing regulatory requirements, as well as associated burdens. It also says that the Notice provides interesting insights and statistics into current SAR reporting. These include that, in 2019, 54% of SAR came from banks and nearly 33% from MSB – meaning that those from other types of organisation were in percentages in single figures, or even less than 1%. It seems that FinCEN also revised its methodology of calculating the burden of filing SAR, including the time and effort estimates involved in the determination not to file a SAR. FinCEN describes 6 stages involved in the filing of a SAR but its cost estimates only try to account for the final 3 stages.
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