On May 4, a covered loan or finance company first detects facts that may provide a basis for a SAR under 31 CFR 1029.320, but identifies no suspect. Assuming the other reporting conditions are met, what are the ordinary deadline and maximum delay allowed to identify a suspect?
Correct Answer
A) File within 30 days, extendable to 60 where no suspect is identified
A. Ordinarily 30 calendar days; up to 60 total when the specified suspect-identification condition applies. Both periods run from the initial detection of reportable facts, not a later internal approval. The additional period is for identifying a suspect; it does not remove the filing duty. Scope and exceptions: The 60 days are total, not 60 extra after day 30. Situations needing immediate attention also require prompt law-enforcement notification under (b)(4). Source: 31 CFR 1029.320(b)(3)–(4) — https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1029/subpart-C/section-1029.320
Why This Is the Correct Answer
A. Ordinarily 30 calendar days; up to 60 total when the specified suspect-identification condition applies. Both periods run from the initial detection of reportable facts, not a later internal approval. The additional period is for identifying a suspect; it does not remove the filing duty. Scope and exceptions: The 60 days are total, not 60 extra after day 30. Situations needing immediate attention also require prompt law-enforcement notification under (b)(4).
Why the Other Options Are Wrong
Option B: File within 90 days, which is the period where no suspect is known
Ninety days is not this initial-filing deadline.
Option C: File within 5 business days, the same period as an error acknowledgement
Five business days is not the SAR deadline.
Option D: No filing is required at all until a suspect has actually been identified
An unidentified suspect does not permit indefinite delay.
Exam Tip
Track the initial-detection date and the limited reason for any extension.
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