Why are certain value missing in the downloadable FinCEN SAR PDF?
The SAR PDF available in a Case is for reference only — it isn’t the version submitted to FinCEN. The official filing comes from the SAR XML report, which contains the full and accurate data.
Why don't these values appear?
FinCEN’s SAR PDF format includes proprietary features that stop Hummingbird from auto-filling a few date fields as well as attachment names. We still provide this PDF as it’s simple to view, share, and reference alongside your case work.
As of this writing, the following values may not populate:
Subject Dates of Birth
Action Date (item 26)
IP Address date (item 43)
Names of the Files attached to the SAR
Although these dates are not being populated in the SAR PDF, it does not mean that they are not being transmitted to FinCEN.
What is actually sent to FinCEN?
Hummingbird electronically submits SAR/CTR reports to FinCEN via the BSA E-Filing system. The submission is transmitted using an XML report, this report will contain all the missing values mentioned in this article.
How can I confirm the values are in the XML Report?
The best way to review SARs being sent to FinCEN is to download the FinCEN SAR XML Format. The XML is the official filing that Hummingbird submits to FinCEN.
Within the FinCEN SAR XML Format, the date of birth should be populated in an XML entry labeled <fc2:IndividualBirthDateText>
. You can search for the IndividualBirthDateText element and see the date formatted as a 4 digit year, 2 digit month, and 2 digit day with no delimiters.
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