Why aren’t the dates of birth for subjects populating in the FinCEN SAR PDF?
The SAR PDF that FinCEN provides uses some proprietary PDF features that prevent Hummingbird from populating certain date fields automatically, including dates of birth. Although dates of birth are not being populated in the SAR PDF, it does not mean that they are not being transmitted to FinCEN.
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.
Are there other known fields missing from the SAR PDF?
Under Subject Information, 'Action date' (item 26) and 'IP Address date' (item 43) also do not populate on the PDF. In addition, the names of the files attached to the SAR also do not populate on the Home page of the PDF at this time. Similar to date of birth, these fields populate on the SAR XML and are transmitted to FinCEN.
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