We use Verafin and when filing a SAR, the address information will pull from the core into the SAR as follows: Part IV Filing Institution Contact Information: in this section our main office address appears. Part III Information about Financial Institution Where Activity Occurred, In this section the branch address where the account is assigned to will appear (this is usually where the member opened their account, or where the account was reassigned because the member does most of their business there). Our Compliance Officer is saying the Main Office address should appear in Part III, not the address where the account is assigned to. We have never had any issues from regulators, auditors, etc. My opinion is it is fine that it is the branch address where the account is assigned, we are the filing institution and the main office address appears in Part IV. My question to you is: What does your institution put as the address in Part III if you assign accounts to branches? Thanks for your help!
February 2, 2017 - 2:06pm
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