[18093]
October 12, 2004
TO: OPERATIONS COMMITTEE No. 20-04
TRANSFER AGENT ADVISORY COMMITTEE No. 77-04
RE: 2004 SUSPICIOUS ACTIVITY REPORTING (SAR) SURVEY
The Transfer Agent Advisory Committee established a task force, chaired by Lori
Burgess of Delaware Service Company, who developed the 2004 Suspicious Activity Reporting
(SAR) Survey. This survey is designed to gather information regarding mutual fund transfer
agents’ current procedures for monitoring suspicious activity in the context of anti-money
laundering compliance obligations. The survey is organized to collect data from respondents
with respect to transaction review procedures, pattern activity procedures, account specific
procedures, investment acceptance procedures, cash (currency) and cash equivalent procedures
and SAR reporting and follow-up procedures.
We are requesting that both Operations Committee and Transfer Agent Advisory
Committee member complexes complete the 2004 SAR Survey in order to obtain responses from
a broad cross-section of the industry. Operations Committee and Transfer Agent Advisory
Committee members at the same complex should coordinate their responses and complete only
one online survey response for your organizations. Members are encouraged to solicit input
from their anti-money laundering compliance departments, as well as their representatives that
participate on the ICI’s Money Laundering Rules Working Group.
This is a web-only survey. Survey participants may access the survey using their user
name and password for the ICI members’ website. If you currently do not have access to the
member site, please contact Lee Butler by email or phone (both noted below). The SAR survey
is located at http://operations.ici.org/survey/sar.jsp. This online survey is designed to be
completed using Microsoft Internet Explorer. A blank survey document (printable PDF
version) is available online for reference purposes only. Please submit your completed SAR
Survey response online to the Institute no later than November 12, 2004. When you have
finished the survey, you will be able to print out a complete copy of your responses.
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If you have any questions regarding the survey, please direct your inquiries to the
following Institute staff:
Technical Issues (web entry of the survey) – Lee Butler at lbutler@ici.org or
202-326-5931.
Survey Content Issues – Diane Butler at butler@ici.org or 202-326-5850.
As with all ICI surveys, this survey solicits data from members for informational
purposes only. Data collected from each individual firm will remain confidential and only
aggregate survey results will be reported to members. Each member should independently
review and utilize such aggregated data, as it deems appropriate.
We encourage all Operations Committee and Transfer Agent Advisory Committee
members to complete the Suspicious Activity Reporting Survey. The aggregate survey results
will be shared with ICI committees and working group members and discussed at future
meetings.
Diane M. Butler
Director – Transfer Agency
& International Operations