Regulatory Alerts2009-03-09
Added
Interpretive Guidance on Sharing Suspicious Activity Reports by Securities Broker-Dealers, Mutual Funds, Futures Commission Merchants, and Introducing Brokers with Certain U.S. Affiliates
This proposed interpretive guidance permits securities broker-dealers, mutual funds, futures commission merchants, and introducing brokers in commodities to share a Suspicious Activity Report (SAR) or information revealing its existence with affiliates that are subject to a SAR regulation. The sharing is restricted to the entity that filed the SAR and prohibits recipients from further disclosing the SAR to other affiliates, even if those affiliates are also subject to SAR rules. The guidance requires entities to maintain written confidentiality agreements and appropriate internal controls to ensure affiliates protect the confidentiality of the shared SARs. This proposal is issued for public comment with a deadline of June 8, 2009, and does not impose new requirements or make sharing compulsory.