The Circular File

The Banking Law Prof reminds us that FinCen has delayed the implementation of the new Suspicious Activity Report (SAR) forms from June 30, 2007 "until further notice," to give FinCen and the IRS (there's a pair to draw to!) time to implement a data quality management program. As the Prof wrly observes, "(Well, that's good news if it works!)"

Yeah, you want to know that when you spend the time to fill out and file a SAR, the form you're using has been subjected to a "quality management review" before it's eaten by the FinCen's pet goat.