A residential mortgage company subject to 31 CFR 1029.320 files a SAR on March 2, 2026. Under that section, how long must it retain the report and the identified supporting documentation?
Correct Answer
A) Five years from the date of filing, for the report and its support
A. Retain both for five years from filing. Section 1029.320(c), not subsection (d), establishes this retention period. The requirement includes the SAR copy and original or business-record-equivalent supporting documentation. The filing date—not investigation closure—starts the period. Scope and exceptions: The five-year period reaches March 2, 2031 on these facts; other preservation duties can require longer retention. Supporting records must be identified and available to authorized authorities. SAR confidentiality is separately addressed in subsection (d). Source: 31 CFR 1029.320(c) and (d) — https://www.federalreserve.gov/frrs/regulations/section-1029320-reports-by-loan-or-finance-companies-of-suspicious-transactions.htm
Why This Is the Correct Answer
A. Retain both for five years from filing. Section 1029.320(c), not subsection (d), establishes this retention period. The requirement includes the SAR copy and original or business-record-equivalent supporting documentation. The filing date—not investigation closure—starts the period. Scope and exceptions: The five-year period reaches March 2, 2031 on these facts; other preservation duties can require longer retention. Supporting records must be identified and available to authorized authorities. SAR confidentiality is separately addressed in subsection (d).
Why the Other Options Are Wrong
Option B: Five years, though supporting documents may be purged after 1 year
Supporting documentation has the same five-year requirement.
Option C: Until the investigation closes, with no fixed period in the rule
Closure of an investigation does not replace the specified period.
Option D: Three years from filing, matching the general loan file retention
Three years is not this SAR retention rule.
Exam Tip
SAR retention: report plus support, five years from filing; confidentiality is a separate obligation.
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