WASHINGTON - The new Suspicious Activity Report - a filing banks will use to alert federal officials to questionable transactions - will not be ready on Oct. 1, as expected.

Federal Reserve Board officials said the report is still being developed and will not be available until December.

The three-page report will replace the Criminal Referral Form and a box on Currency Transaction Reports that banks have been checking and backing up with documentation explaining the suspicious activity.

When a new currency report - without the box - takes effect on Oct. 1, banks will use the current Criminal Referral Form to report suspected crimes, according to the Fed's deputy associate director for enforcement, Herbert A. Biern.

In a Sept. 6 letter to supervisors at the Fed's 12 regional banks, Mr. Biern said, "Banking organizations should also be advised that because they can no longer report suspicious currency transactions on the Treasury's CTR form as of Oct. 1, 1995, they should use the current criminal referral form to report suspicious financial transactions that would have previously been reported by checking the suspicious box on the old CTR form."

The suspicious activity forms are designed to centralize the reporting process and ease banks' paperwork burdens by allowing banks to send the reports - on paper or through a computer - to the Treasury Department's Financial Crimes Enforcement Network. Previously, banks had to send copies to as many as seven places.

The government also is raising the threshold for reporting a suspicious activity from $1,000 to $5,000 if the bank has a "substantial basis" for identifying the suspect, and from $5,000 to $25,000 if there is no basis for the report. But there is still no threshold for reporting suspicious acts by insiders and violations of the Bank Secrecy Act.

All four regulatory agencies are releasing separate rules on suspicious reports, but the various rules are nearly identical.

Bankers' reaction to the changes vary, depending on the size of the institution.

John J. Byrne, senior federal legislative counsel for the American Bankers' Association, praised the changes in the rules in a comment letter to the Fed and the Office of the Comptroller of the Currency.

However, Richard L. Mount, president of the Independent Bankers Association of America, expressed deeper concerns in his letter to the Fed.

His worries included: the security of the data base in which Fincen will keep incoming information; placing the burden of judgment of banks; and potentially adding more paperwork by removing the box from the currency report and creating the new form.

"It is not completely clear at this point that community banks will reap a great deal of benefit and the lost option of checking off a box on the CTR may mean that some banks actually have to complete a new form," he noted.

Mr. Mount also recommended reviewing the changes after 12 to 18 months.

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