Requirements for Correcting Errors in Electronically Batch-Filed Suspicious Activity Reports

1 FIN-2009-G005 Issued: December 10, 2009 (Amended December 14, 2009) Subject: Requirements for Correcting Errors in Electronically Batch-Filed Suspicious Activity Reports The Financial Crimes Enforcement Network (FinCEN) is issuing these guidelines to assist users of the Bank Secrecy Act (BSA) E-Filing System in correcting errors in batch-filed Suspicious Activity Reports (SARs)1 . Background: On September 12, 2009, FinCEN implemented a system for providing acknowledgements to filers for Suspicious Activity Reports (SARs) filed through the BSA E-Filing System. The acknowledgements, similar to those for Currency Transaction Reports (CTR), provide filers with evidence that their SARs were received. SAR acknowledgements include the Document Control Number (DCN) assigned to each document. Discrete BSA E-filers receive acknowledgements automatically. Batch BSA E-Filers must sign up to receive acknowledgement files that contain a record with DCNs for each SAR in their batch files.2

On December 12, 2009, FinCEN will implement data validation on all batch-filed SARs. All batch filers will receive E-mail notifications when there are errors in their submitted SAR batch files.3 Filers signed up to receive acknowledgements will also receive error notifications in their acknowledgement files.4 The following guidelines provide batch filers with the requirements for correcting errors identified in submitted batch files and preventing errors in future submissions.

1 For purposes of this document, “SAR” collectively refers to the Suspicious Activity Report by Casinos and Card Clubs (SAR-C), the depository institution Suspicious Activity Report (SAR-DI), the Suspicious Activity Report by Money Services Business (SAR-MSB), and the Suspicious Activity Report by the Securities and Futures Industries (SAR-SF). 2 Complete details on BSA E-filing SAR acknowledgements are found in the document “BSA E-Filing System SAR Acknowledgements and Validations Questions and Answers Guide” available on BSA E-Filing’s public Internet site at http://bsaefiling.fincen.treas.gov/main.html. 3 These notifications state that batch files were accepted with warnings, i.e. that they contained errors. Filers can obtain the batch file error lists through the Track Status Page and Submission Errors Page in the BSA E-Filing System. 4 Discrete BSA E-Filers will not receive error codes in their acknowledgements because the discrete BSA E-Filing SAR forms are designed to prevent the types of errors being looked for in batch files.

2 Error Categories: For purposes of these guidelines, errors have been divided into primary and secondary categories. Primary errors are those that so degrade the quality of the SAR data that they must be corrected. Primary errors make it difficult for analysts and law enforcement investigators to locate the SARs in the database or identify the nature and circumstances of the suspicious activity. Examples of such errors include blank narratives, missing financial institution Employer Identification Numbers, or formatting errors. FinCEN requires that filers submit corrected SARs for all SARs containing primary errors. Secondary errors are those that violate electronic filing requirements or form instructions but do not seriously degrade the quality of the SAR data. Examples of secondary errors are ZIP Codes that end in four zeros (e.g. 123450000), blank or invalid filer branch information, or invalid subject telephone numbers. FinCEN requires that filers prevent reported secondary errors in their future filings. Filers should not submit a corrected SAR if a SAR contains only secondary errors, but they should correct secondary errors found in a SAR that also contains primary errors. Correction Requirements: Filers must submit corrected SARs through the BSA E-Filing System. FinCEN recommends that primary error corrections be made no later than 30 days after receiving error notifications. Furthermore, FinCEN recommends that filers remedy any systemic problems in their electronic submissions within 30 days of receiving error notifications. If technical issues prevent filers from implementing corrections within these time frames, they should notify FinCEN by writing to: Financial Crimes Enforcement Network Office of Compliance P.O. Box 39 Vienna, VA 22183. This notification should explain the technical issues involved, why the time frame(s) cannot be met, provide an estimate of when the issues will be resolved, and include a contact name and telephone number. Correction Procedures: Filers must prepare corrected SARs using the following procedures: • Make the corrections to the SAR data that contain errors. • Include a description of the correction in the narrative.

3 • Filers who receive SAR acknowledgements must include the DCN of the original SAR in the narrative. • Check box 1 to indicate that the SAR corrects a previous SAR filing. • Change the “Date report prepared” (SAR-C, SAR-DI, and SAR-SF) or “Date filed” (SAR-MSB) to the current date. BSA E-Filer Support: The BSA E-Filing System Help Desk will provide technical support for all users. The BSA E￾Filing Help Desk can be contacted by calling 1-888-827-2778 (option 6) or by email at BSAEFilingHelp@notes.tcs.treas.gov. The Help Desk’s regular hours of operation are 8:00 a.m. to 6:00 p.m. East Coast Time, Monday through Friday. Please note that the Help Desk is closed on Federal holidays. Users can address general questions about preparing corrected SARs to FinCEN’s Regulatory Helpline at 1-800-949-2732. Helpline staff is available from 8 a.m. to 5 p.m. East Coast Time, Monday through Friday. The office is closed on Federal holidays. Primary and Secondary SAR Errors: The following appendices list the primary and secondary errors for each SAR form. Appendix A: Guidelines for Correcting Errors in the Electronically-Batch Filed Suspicious Activity Report by Casinos and Card Clubs, FinCEN Form 102. Appendix B: Guidelines for Correcting Errors in Electronically-Batch Filed Suspicious Activity Reports, TD F 90-22.47. Appendix C: Guidelines for Correcting Errors in the Electronically-Batch Filed Suspicious Activity Report by Money Services Business, FinCEN Form 109. Appendix D: Guidelines for Correcting Errors in Electronically-Batch Filed Suspicious Activity Reports by the Securities and Futures Industries, FinCEN Form 101. [UPDATE: As of July 31, 2010, the toll free number for the BSA E-Filing Service Desk is 1-866-346-9478 (Option 1). The email address is now BSAEFilingHelp@fincen.gov.]

4 Appendix A: Requirements for Correcting Errors in the Electronically-Batch Filed Suspicious Activity Report by Casinos and Card Clubs, FinCEN Form 102. The Financial Crimes Enforcement Network (FinCEN) is issuing these guidelines to assist users of the Bank Secrecy Act (BSA) E-Filing System in correcting errors in batch-filed Suspicious Activity Reports by Casinos and Card Clubs (SAR-C), FinCEN Form 102. Primary Errors: The following SAR-C errors are primary and must be corrected. Error Code Error Description1 Record Field Position Form Field Number A01 "Casino/Card Club Trade" Name is missing. 2A 8 – 42 32 A06 "Casino/Card Club EIN" is missing or invalid. 2A 144 – 152 34 A11 "Contact Area Code" is missing or invalid. 2A 250 – 252 44 A12 "Contact telephone" is missing or invalid. 2A 253 - 259 44 A19 "From Suspicious Activity Date" is missing, invalid, more recent than the "To Suspicious Activity Date," or more recent than the "Prepared Date." 3A 97 – 104 24 A21 "Suspicious Activity Amount" is missing or invalid. 3A 113 – 122 25 A22 "Suspicious Activity Type" is missing, is invalid, or has duplicates. 3A 123 – 139 26 A26 "Subject's Name" is missing. 4A 8 – 42 3-5 A32 "Subject's TIN" is invalid. 4A 146 - 154 14 A49 "Explanation/Description" of the suspicious activity is missing or contains one or more blank records. 6A 8 - 403 Part VI

1 An error description of “missing” indicates that a required value is not present. “Invalid” indicates an entered value does not match the electronic filing requirements or form instructions. Examples of invalid values include a check box value of “X” when it should be “A” or “B,” a date in an incorrect format, a Social Security Number consisting of all nines, or a ZIP Code ending with four zeros.

5 Secondary Errors: The following SAR-C errors are secondary. They must be corrected only when there are primary errors in the same SAR-C. Error Code Error Description2 Record Field Position Form Field Number A02 "Casino or Card Club" Address is missing. 2A 78 – 07 35 A03 "Casino/Card Club" City is missing. 2A 108 - 132 36 A04 "Casino/Card Club State" is missing or invalid. 2A 133 - 134 37 A05 "Casino/Card Club ZIP Code" is missing or invalid. 2A 135 – 143 38 A07 "Type of Gaming Casino or Card Club" is invalid. 2A 153 – 154 39 A08 "Type of Gaming Other Description" is missing when "Type of Gaming Casino or Card Club" is "D." 2A 155 – 174 39d A09 "Contact Name" is missing. 2A 175 – 209 40-42 A13 "Prepared Date" is missing, invalid, or more recent than current date. 2A 260 - 267 45 A14 "Enforcement Agency Code" is invalid. 3A 8 27 A15 "Enforcement Agency Name" is missing when the "Enforcement Agency Code" is "B" or "G" through "L”. 3A 9 – 43 27 A16 "Enforcement Agency Contact Area Code” is invalid. 3A 79 – 81 30 A17 "Enforcement Agency Contact Phone Number" is invalid. 3A 82 – 88 30 A18 "Enforcement Agency Contact Date" is invalid, more recent than "Prepared Date," or earlier than "From Suspicious Activity Date." 3A 89 – 96 31

2 Ibid.

6 Error Code Error Description Record Field Position Form Field Number A20 “To Suspicious Activity Date” is invalid, earlier than the “From Suspicious Activity Date,” or more recent than the “Prepared Date.” 3A 105 – 112 24 A23 "Corrects Prior Report Indicator" is invalid. 3A 144 – 144 1 A24 "Suspect Information Unavailable" is selected but 4A record exists. 3A 145 – 145 2b A25 "Multiple Subject Indicator" is “X” but contains only one subject record. 3A 146 – 146 2a A27 "Subject's Address" is missing. 4A 78 - 107 8 A28 "Subject's City" is missing. 4A 108 - 132 9 A29 "Subject's State" is missing or invalid. 4A 133 - 134 10 A30 "Subject's ZIP Code" is invalid. 4A 135 - 143 11 A31 "Subject's Country Code" is invalid. 4A 144 - 145 12 A33 "Subject's Date of Birth" is invalid or more recent than the "From Suspicious Activity Date." 4A 155 - 162 16 A34 "Subject's Home Area Code" is invalid. 4A 163 - 165 19 A35 "Subject's Home Phone Number" is invalid. 4A 166 - 172 19 A36 "Subject's Work Area Code" is invalid. 4A 173 - 175 18 A37 "Subject's Work Telephone Number" is invalid. 4A 176 - 182 18 A38 "Subject's Occupation" contains special characters. 4A 213 – 242 7

7 Error Description Record Field Position Form Field Number A39 "Subject’s Identification" is missing or invalid. 4A 243 – 243 17 A40 “Subject’s ID Other Description” is missing when the “Subject’s Identification” value was “D.” 4A 244 – 263 17d A50 "Subject's Identification Number" is missing. 4A 264 – 285 17c A41 "Subject Issuing Authority" is missing or is invalid. 4A 286 – 287 17f A42 "Subject’s Vehicle State Code" is invalid. 4A 296 – 297 13b A51 "Subject’s Account Number" is missing. 4A 298 – 319 15 A43 "Subject No Account Affected Indicator" is invalid. 4A 320 15 A44 "Subject Account Opened Indicator" is missing or invalid. 4A 321 15 A45 "Subject's Relationship Code" is invalid or contains duplicates. 4A 322 – 327 21 A46 "Subject's Affiliation Indicator" is invalid. 4A 328 22 A47 "Subject's Affiliation Code" is missing or invalid. 4A 329 22 A48 "Subject Action Date" is missing, invalid or more recent than "Prepared Date." 4A 330 – 337 23

8 Appendix B: Requirements for Correcting Errors in Electronically-Batch Filed Suspicious Activity Reports, TD F 90-22.47. The Financial Crimes Enforcement Network (FinCEN) is issuing these guidelines to assist users of the Bank Secrecy Act (BSA) E-Filing System in correcting errors in batch-filed depository institution Suspicious Activity Reports (SAR-DI), TD F 90-22.47. Primary Errors: The following SAR-DI errors are primary and must be corrected. Error Code Error Description1 Record Field Position Form Field Number S01 "Financial Institution Name" is missing. 2A 3 - 37 2 S02 "Institution EIN" is missing or invalid. 2A 105 - 113 3 S04 "Primary Federal Regulator" code is invalid. 2A 104 5 S10 "Contact Area Code" is missing or invalid. 2B 161 - 163 49 S11 "Contact Phone Number" is missing or invalid. 2B 164 - 170 50 S14 "From Violation Date" is missing, invalid, or more recent than the “Date Prepared.” 3A 241 - 248 33 S16 "Violation Amount" is missing or not numeric. 3A 257 - 266 34 S17 "Violation Type" is missing, is invalid, or contains duplicates. 3A 267 - 276 35 S40 "Suspect's TIN" is invalid. 4A 118 - 126 19 S59 "Explanation/Description of the suspicious activity" is missing or contains one or more blank records. 6A 15 - 410 Part V Secondary Errors: The following SAR-DI errors are secondary. They must be corrected only when there are primary errors in the same SAR-DI.

1 An error description of “missing” indicates that a required value is not present. “Invalid” indicates an entered value does not match the electronic filing requirements or form instructions. Examples of invalid values include a check box value of “X” when it should be “A” or “B,” a date in an incorrect format, a Social Security Number consisting of all nines, or a ZIP Code ending with four zeros.

9 Error Code Error Description2 Record Field Position Form Field Number S03 "Institution Address" is missing. 2A 38 - 67 4 S05 "Institution City" is missing. 2A 68 - 92 6 S06 "Institution State" is missing or invalid. 2A 93 - 94 7 S07 "Institution ZIP Code" is missing or invalid. 2A 95 - 103 8 S08 "Branch Office State" is invalid. 2B 65 - 66 11 S09 "Branch Office ZIP Code" is invalid. 2B 67 - 75 12 S12 "Contact Name" is missing. The name of at least a contact office must be provided. 2B 86 - 120 45-47 S13 "Corrects Prior Report Indicator" is invalid. 3A 352 1 S15 "To Violation Date" is invalid, more recent than "Date Prepared," or earlier than "From Violation Date." 3A 249 - 256 33 S18 "Amount of Loss" is greater than "Violation Amount" or not numeric. 3A 317 - 326 36 S19 "Amount of Recovery" is greater than "Amount of Loss" or not numeric. 3A 327 - 336 37 S20 "Material Impact Indicator" is not A, B, or blank. 3A 337 38 S21 "Bonding Company Notified" value is not A, B, or blank. 3A 338 39 S22 "Law Enforcement Agencies Advised" is invalid or contains duplicates. 3A 107 - 115 40 S23 "Law Enforcement Agency Phone Number Area Code" is invalid. 3A 186 - 188 42 S24 "Law Enforcement Agency Phone Number" is invalid. 3A 189 - 195 42 S25 "Law Enforcement Agency Phone Number Area Code" is invalid. 3A 231 - 233 44 S26 "Law Enforcement Agency Phone Number" is invalid. 3A 234 - 240 44

2 Ibid.

10 Error Code Error Description Record Field Position Form Field Number S28 "Account Closed Indicator" is missing when an account number was provided, or the indicator is invalid. 3A 37 14a S30 "Account 2 Closed Indicator" is missing when an account number was provided, or the indicator is invalid. 3A 60 14b S32 "Account 3 Closed Indicator" is missing when an account number was provided, or the indicator is invalid. 3A 83 14c S34 "Account 4 Closed Indicator" is missing when an account number was provided, or the indicator is invalid. 3A 106 14d S35 "Violation Type - Other" was selected and description is missing. 3A 277 - 316 35s S36 "Law Enforcement Agency Name" is missing when “Law Enforcement Agencies Advised” contains G, H, or I. 3A 116 - 150 40j S37 "Prepared Date" is missing, invalid, or more recent than the current date. 3A 339 - 346 50 S38 "Multiple Branch Code" is invalid. 3A 351 9 S39 "Suspect Information Unavailable" is selected and a 4A record exists or “Suspect Information Unavailable” is not selected and a 4A record does not exist. 3A 353 Part II S41 "Suspect's State" is invalid. 4A 105 - 106 21 S42 "Suspect's ZIP Code" is invalid. 4A 107 - 115 22 S43 "Suspect's Country" code is invalid. 4A 116 - 117 23 S44 "Suspect's Area Code" is invalid. 4A 135 - 137 24 S45 "Suspect's Phone Number" is invalid. 4A 138 - 144 24 S46 "Suspect's Work Area Code" is invalid. 4A 145 - 147 25 S47 "Suspect's Work Phone Number" is invalid. 4A 148 - 154 25 S48 "Suspect’s Occupation" contains invalid characters. 4A 155 - 184 26

11 Error Code Error Description Record Field Position Form Field Number S49 "Suspect's Date of Birth" is invalid, or more recent than the "Date Prepared." 4A 127 - 134 27 S50 "Suspect Admission/Confession Indicator" is not A, B, or blank. 4A 304 28 S51 "Suspect’s Identification" value is not A, B, C, D, or blank. 4A 185 29 S52 "Suspect ID Issuing Authority" is invalid. 4A 248 - 249 29 S53 "Suspect’s ID Other" was selected and description is missing. 4A 186 - 225 29d S54 "Suspect’s Relationship" is invalid or contains duplicates. 4A 250 - 253 30 S55 "Suspect’s Relationship Other" was selected and description is missing. 4A 254 - 293 30L S56 "Suspect’s Affiliation" value is not A, B, or blank. 4A 294 31 S57 "Suspect’s Affiliation" is an insider relationship, and "Suspect's Affiliation Code" is missing or invalid. 4A 295 31 S58 "Suspect Termination Date" is missing or invalid when the "Suspect's Affiliation Code" is D, E, or F. 4A 296 - 303 32

12 Appendix C: Requirements for Correcting Errors in the Electronically-Batch Filed Suspicious Activity Report by Money Services Business, FinCEN Form 109. The Financial Crimes Enforcement Network (FinCEN) is issuing these guidelines to assist users of the Bank Secrecy Act (BSA) E-Filing System in correcting errors in batch-filed Suspicious Activity Reports by Money Services Business (SAR-MSB), FinCEN Form 109. Primary Errors: The following SAR-MSB errors are primary and must be corrected. Error Code Error Description1 Record Field Position Form Field Number M02 "Reporting Business Name" is missing or invalid. 2A 4-58 35 M08 "Reporting Business EIN or SSN/TIN (Individual)" is missing or invalid, or the value is “XX” when the “Reporting Business Country" is blank or “US.” 2A 202 - 210 41 M09 "Reporting Business Phone" number is missing or invalid. 2A 211 - 220 42 M11 "Transaction Location Legal Name" is missing or invalid. 2B 10 - 64 24 M17 "Transaction Location EIN or SSN/ITIN (Individual)" is missing or invalid. 2B 208 - 216 30 M18 "Transaction Location Business Phone Number" value is missing or invalid. 2B 217 - 226 31 M29 "From Violation Date" is missing, invalid, or more recent than "Date Filed." 3A 13 - 20 16 M31 "Violation Amount Value" is missing or invalid. 3A 29 - 43 17 M33 "Category of Suspicious Activity" is missing, is invalid, or has duplicates. 3A 45 - 48 18

1 An error description of “missing” indicates that a required value is not present. “Invalid” indicates an entered value does not match the electronic filing requirements or form instructions. Examples of invalid values include a check box value of “X” when it should be “A” or “B,” a date in an incorrect format, a Social Security Number consisting of all nines, or a ZIP Code ending with four zeros.

13 Error Code Error Description Record Field Position Form Field Number M39 "Contact Telephone Number" is missing or invalid. 3A 169 - 178 46 M45 "Subject’s Last Name or Entity Full Name" is missing. 4A 15 - 49 4 M53 "Subject’s SSN/ITIN/EIN" is missing or invalid. 4A 223 - 231 13 M59 "Explanation/Description of the suspicious activity" is missing or contains one or more blank records. 7A 13 - 470 Part VI Secondary Errors: The following SAR-MSB errors are secondary. They must be corrected only when there are primary errors in the same SAR-MSB.

Error Code Error Description2 Record Field Position Form Field Number M01 "Reporting Business same as Transaction Location Indicator" is checked but Reporting Business Name and Address information is not blank or "Reporting Business same as Transaction Location Indicator" is invalid. 2A 3 34 M03 "Reporting Business Address" is missing or invalid. 2A 114-163 37 M04 "Reporting Business City" is missing or invalid. 2A 164-188 38 M05 "Reporting Business State" is missing or invalid. 2A 189-190 39 M06 "Reporting Business ZIP" is missing or invalid. 2A 191-199 40 M07 "Reporting Business Country" is invalid. 2A 200-201 43 M10 "Type of Business Location" is invalid. 2B 9 23 M12 "Transaction Location Permanent Address" is missing or invalid. 2B 120 - 169 26 M13 "Transaction Location City" is missing or invalid. 2B 170 - 194 27 M14 "Transaction Location State" is missing or invalid. 2B 195 - 196 28 M15 "Transaction Location ZIP Code" is missing or invalid. 2B 197 - 205 29

2 Ibid.

14 Error Code Error Description Record Field Position Form Field Number M16 "Transaction Location Country" is missing or invalid. 2B 206 - 207 32 M19 "Multiple Transaction Locations" is invalid. 2B & 2C 8 22 M20 "Type of Business Location" is invalid. 2C 9 23 M21 "Transaction Location Legal Name" of business is missing. 2C 10 - 64 24 M22 "Transaction Location Permanent Address" is missing. 2C 120 - 169 26 M23 "Transaction Location City" is missing. 2C 170 - 194 27 M24 "Transaction Location State" is missing or invalid. 2C 195 - 196 28 M25 "Transaction Location ZIP Code" is missing or invalid. 2C 197 - 205 29 M26 "Transaction Location Country" is invalid. 2C 206 - 207 32 M27 "Transaction Location EIN" is missing or invalid. 2C 208 - 216 30 M28 "Transaction Location Business Phone Number" is missing or invalid. 2C 217 - 226 30 M30 "To Violation Date" is invalid, more recent than "Date Filed," or earlier than "From Date." 3A 21 - 28 16 M32 "Violation Amount Unknown" value is invalid. 3A 44 17a M34 "Other category of Suspicious Activity" is missing when "Category of Suspicious Activity" contains "Z." 3A 49 - 73 18z M35 "Financial Services Involved" is missing, is invalid, or has duplicates. 3A 74 - 78 19 M36 “Other” is missing when “Financial Services Involved” contains “Z.” 3A 79 - 103 19z M37 "Character of Suspicious Activity Continued" is invalid or has duplicates. 3A 104 - 113 19 M38 "Contact Office" is missing. 3A 114 - 168 45 M40 "Date Filed" is missing, invalid, or more recent than date transmitted. 3A 179 - 186 47 M41 "Amending/Correcting Indicator" is invalid. 3A 248 1 M42 "Recurring Report Indicator" is invalid. 3A 249 1a

15 Error Code Error Description Record Field Position Form Field Number M43 "Multiple Subjects Indicator" is invalid or there is only one subject. 4A 13 2 M44 "Subject’s Type" is invalid or missing. 4A 14 3 M46 "Subject’s First Name" is missing. 4A 50 - 68 5 M47 "Subject’s Address" is missing. 4A 70 - 119 7 M48 "Subject’s City" is missing. 4A 120 - 144 8 M49 "Subject’s State" is missing or invalid. 4A 145 - 146 9 M50 "Subject’s ZIP Code" is missing or invalid. 4A 147 - 155 10 M51 "Subject’s Country" is invalid. 4A 156 - 157 11 M52 "Subject’s Identification" is missing or invalid. 4A 158 12 M54 "Subject’s Date of Birth" is missing, invalid, or more recent than "Date Filed." 4A 232 - 239 14 M55 "Subject’s Telephone Number" is invalid. 4A 240 - 249 15 M56 "Subject’s Identification Number" is missing. 4A 199 - 220 12e M57 "Subject's Issuing State/Country" is missing or invalid. 4A 221 - 222 12f M58 "Subject’s ID Other Description" is missing. 4A 159 - 198 12z B01 "Money Order1" is invalid. 5A 13 20 B02 "Issuer Name1" value is not the Issuer Name. 5A 14 - 68 20 B03 "Total Instruments1" is invalid. 5A 69 - 71 20 B04 "Total US Dollars Amount1" is invalid. 5A 72 - 86 20 B05 "Money Orders2" is invalid. 5A 87 20 B06 "Issuer Name2" value is not the Issuer Name. 5A 88 - 142 20 B07 "Total Instruments2" is invalid. 5A 143 - 145 20 B08 "Total US Dollars Amount2" is invalid. 5A 146 - 160 20 B09 "Money Order3" is invalid. 5A 161 20 B10 "Issuer Name3" value is not the Issuer Name. 5A 162 - 216 20 B11 "Total Instruments3" is invalid. 5A 217 - 219 20 B12 "Total US Dollars Amount3" is invalid. 5A 220 - 234 20

16 Error Code Error Description Record Field Position Form Field Number B13 "Traveler’s Checks1" is invalid. 5B 13 20 B14 "Issuer Name1" value is not the Issuer Name. 5B 14 - 68 20 B15 "Total Instruments1" is invalid. 5B 69 - 71 20 B16 "Total US Dollars Amount1" is invalid. 5B 72 - 86 20 B17 "Traveler’s Checks2" is invalid. 5B 87 20 B18 "Issuer Name2" value is not the Issuer Name. 5B 88 - 142 20 B19 "Total Instruments2" is invalid. 5B 143 - 145 20 B20 "Total US Dollars Amount2" is invalid. 5B 146 - 160 20 B21 "Traveler’s Checks3" is invalid. 5B 161 20 B22 "Issuer Name3" value is not the Issuer Name. 5B 162 - 216 20 B23 "Total Instruments3" is invalid. 5B 217 - 219 20 B24 "Total US Dollars Amount3" is invalid. 5B 220 - 234 20 B25 "Money Transfers1" is invalid. 6A 13 20 B26 "Issuer Name1" value is not the Issuer Name. 6A 14 - 68 20 B27 "Total Instruments1" is invalid. 6A 69 - 71 20 B28 "Total US Dollars Amount1" is invalid. 6A 72 - 86 20 B29 "Money Transfers2" is invalid. 6A 87 20 B30 "Issuer Name2" value is not the Issuer Name. 6A 88 - 142 20 B31 "Total Instruments2" is invalid. 6A 143 - 145 20 B32 "Total US Dollars Amount2" is invalid. 6A 146 - 160 20 B33 "Money Transfers3" is invalid. 6A 161 20 B34 "Issuer Name3" value is not the Issuer Name. 6A 162 - 216 20 B35 "Total Instruments3" is invalid. 6A 217 - 219 20 B36 "Total US Dollars Amount3" is invalid. 6A 220 - 234 20 B37 "Bulk Small Indicator1" is invalid. 6B 13 21 B39 "Tendered Country1" is invalid. 6B 34 - 35 21 B41 "Received Country1" is invalid. 6B 56 - 57 21

17 Error Code Error Description Record Field Position Form Field Number B42 "US Dollars Amount1" is invalid. 6B 58 - 72 21 B43 "Bulk Small Indicator2" is invalid. 6B 73 21 B45 Tendered Country2 is invalid. 6B 94 - 95 21 B47 "Received Country2" is invalid. 6B 116 - 117 21 B48 "US Dollars Amount2" is invalid. 6B 118 - 132 21

18 Appendix D: Requirements for Correcting Errors in Electronically-Batch Filed Suspicious Activity Reports by the Securities and Futures Industries, FinCEN Form 101. The Financial Crimes Enforcement Network (FinCEN) is issuing these guidelines to assist users of the Bank Secrecy Act (BSA) E-Filing System in correcting errors in batch-filed Suspicious Activity Reports by the Securities and Futures Industries (SAR-SF), FinCEN Form 101. Primary Errors: The following SAR-SF errors are primary and must be corrected. Error Code Error Description1 Record Field Position Form Field Number R01 "Institution Name" is missing. 2A 3 – 37 36 R06 "Institution EIN" is missing or invalid. 2A 104 – 112 37 R18 "From Violation Date" is missing, invalid, or more recent than "Prepared Date." 3A 15 – 22 21 R20 "Total Dollar Amount" is missing or invalid. 3A 31 – 40 22 R25 "Violation Type" is missing, is invalid, or has duplicate entries. 3A 177 – 196 30 R34 "Contact Work Area Code" is missing or invalid. 3A 418 - 420 56 R35 "Contact Work Phone Number" is missing or invalid. 3A 421 - 427 56 R37 "Subject's Name" is missing or invalid. 4A 13 – 47 3-5 R44 "Subject’s TIN" is missing or invalid. 4A 211 – 219 14 R63 "Explanation/Description" of the suspicious activity is missing or contains one or more blank records. 5A 13 - 510 Part VI Secondary Errors: The following SAR-SF errors are secondary. They must be corrected only when there are primary errors in the same SAR-SF.

1 An error description of “missing” indicates that a required value is not present. “Invalid” indicates an entered value does not match the electronic filing requirements or form instructions. Examples of invalid values include a check box value of “X” when it should be “A” or “B,” a date in an incorrect format, a Social Security Number consisting of all nines, or a ZIP Code ending with four zeros.

19 Error Code Error Description2 Record Field Position Form Field Number R02 "Institution Address" is missing. 2A 38 – 67 38 R03 "Institution City" is missing. 2A 68 – 92 39 R04 "Institution State" is missing or invalid. 2A 93 – 94 40 R05 "Institution ZIP Code" is missing or invalid. 2A 95 – 103 41 R07 Transmitter Control Code is missing. 2A 113 – 120 R08 "Central Registration Depository Number" is invalid. 2A 121 – 131 47 R09 "SEC ID Number" is invalid. 2A 132 – 140 48 R10 "National Futures Association ID Number" is invalid. 2A 141 – 148 49 R12 "Multiple Branches" is invalid. 2B 38 43 R14 "Branch Office State" is invalid. 2B 64 – 65 45 R15 "Branch Office ZIP Code" is invalid. 2B 66 – 74 46 R16 "Report Indicator" is missing or invalid. 3A 13 1 R17 "Multiple Subject or Subject Information Unavailable" is invalid. 3A 14 2a/b R19 "To Violation Date" is invalid, earlier than the "From Violation Date," or more recent than "Prepared Date." 3A 23 – 30 21 R21 "Type of Instrument" is invalid or has duplicate entries. 3A 41 – 60 23 R22 "Commodity Type" is missing when "Type of Instrument" is 'Q'. 3A 61 – 80 23q R23 "Instrument Description" is missing when "Type of Instrument" is 'R'. 3A 81 – 100 23r R24 "Market Where Traded" is missing when "Type of Instrument" is 'S'. 3A 101 – 104 23s

2 Ibid.

20 Error Code Error Description Record Field Position Form Field Number R26 "Enforcement Agency Contacted" is invalid or has duplicate entries. 3A 197 - 214 31 R27 "Other Authority Contacted Or US Attorney Office" is missing when "Enforcement Agency Contacted" is B or L-R. 3A 215 – 249 32 R28 "Contact Phone Number" is invalid. 3A 285 – 294 34 R29 "Date Contacted" is invalid or more recent than "Date Prepared." 3A 295 – 302 35 R30 "Has Reporting Individual/ Entity Coordinated This Report With Another Individual/ Entity" is invalid. 3A 303 50 R31 "Type of Institution" is invalid or has duplicate entries. 3A 304 – 357 51 R32 "Contact for Assistance Name" is missing. 3A 358 - 392 52-54 R33 "Contact Title/Position" is missing. 3A 393 - 417 55 R36 "Prepared Date" is missing or invalid. 3A 428 - 435 57 R38 "Subject’s Occupation" - no special characters allowed. 4A 83 –112 7 R39 "Subject’s Address" is missing. 4A 113 - 142 8 R40 "Subject’s City" is missing. 4A 143 - 167 9 R41 "Subject’s State" is missing or invalid. 4A 168 - 169 10 R42 "Subject’s ZIP Code" is missing or invalid. 4A 170 – 178 11 R43 "Subject’s Country" is invalid. 4A 179 – 180 12 R45 "Subject Account Number 1" is missing. 4A 220 – 237 15 R46 "Subject Account Number 1 Closed" is invalid. 4A 238 15 R47 "Subject Account Number 2" is missing when "Subject Account Number 2 Closed" is "Y." 4A 239 – 256 15 R48 "Subject Account Number 2 Closed" is invalid. 4A 257 15

21 Error Code Error Description Record Field Position Form Field Number R49 "Subject Account Number 3" is missing when "Subject Account Number 3 Closed" is "Y." 4A 258 – 275 15 R50 "Subject Account Number 3 Closed" is invalid. 4A 276 15 R51 "Subject Account Number 4" is missing when "Subject Account Number 4 Closed" is "Y." 4A 277 – 294 15 R52 "Subject Account Number 4 Closed" is invalid. 4A 295 15 R53 "Subject’s Date of Birth" is invalid or more recent than the "Date Filed." 4A 296 – 303 16 R54 "Subject's ID" is missing or invalid. 4A 304 17 R55 "Subject’s ID Other Description" is missing. 4A 305 – 344 17e R56 "Subject's ID Number" is missing. 4A 345 – 366 17f R57 "Subject’s Issuing Authority" is missing or invalid. 4A 367 – 368 17g R58 "Subject’s Work Area Code" is invalid. 4A 369 – 371 18 R59 "Subject’s Work Phone" is invalid. 4A 372 – 378 18 R60 "Subject’s Area Code" is invalid. 4A 379 – 381 19 R61 "Subject’s Phone Number" is invalid. 4A 382 – 388 19 R62 "Subject's Association" is invalid. 4A 389 20