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Part I: Institution Information

Part I: Institution Information 2025

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The document is an Audit Certification for the Borrower-in-Custody (BIC) Program, detailing institutional information, pledge arrangements, documentation management, collateral oversight, and compliance procedures. It includes sections on loan types pledged, tracking exceptions in documentation, storage of payment documents, monitoring processes for pledged loans, and certification of compliance with BIC guidelines. The document aims to ensure that institutions adhere to Federal Reserve requirements regarding collateral management and reporting.

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How many days to file a SAR?

Beneficial ownership information reporting requirements are now back in effect, with a new deadline of March 21, 2025, for most companies. Prior to March 21, 2025, FinCEN will assess its options for further modifying deadlines.

What should be included in a narrative report?

The narrative description must include sufficient detail to ensure future queriers have a clear understanding of what the subject of the report is alleged to have done, and the nature of events and reasons for the action upon which the report is based.

What should be included in a SAR narrative?

Facts presented in the SAR narrative clearly support the purpose of the SAR filing. The narrative includes information on disposition on further actions by the financial institution and identifies the availability and location of documentation supporting the SAR.

Do banks still need to collect beneficial ownership information?

An effective SAR has five vital components2: Introduction. The introduction to a SAR should begin with the reason for the filing, including the type of activity being reported. Account Information. Due Diligence/Investigation. Dates and Activity. Closing Statement and Conclusion.

What information should be included in a SAR?

Key Elements of a Narrative Report A clear and concise thesis statement. A well-developed plot that includes conflict, resolution, and . Strong characters that drive the narrative. Descriptive language and sensory details.

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