OperationsSuspicious Activity Reports and Other Reports and Statements

SUMMARY: The Office of Thrift Supervision (OTS) is proposing to amend

its regulations to implement a new interagency suspicious activity

referral process and to update and clarify the underlying reporting

regulation. The proposal reduces substantially the burden on savings

associations and service corporations in reporting suspicious

activities while enhancing access to such information by the Federal

law enforcement agencies, the Federal financial institutions

supervisory agencies, and the Department of the Treasury.

DATES: Comments must be received by September 15, 1995.

ADDRESSES: Comments should be sent to: Chief, Dissemination Branch,

Records Management and Information Policy, Office of Thrift

Supervision, 1700 G Street, NW., Washington, DC 20552, Attention Docket

No. 95-145. These submissions may be hand-delivered to 1700 G Street,

NW., from 9:00 A.M. to 5:00 P.M. on business days; they may be sent by

facsimile transmission to FAX Number (202) 906-7755. Comments will be

available for inspection at 1700 G Street, NW., from 1:00 P.M. until

4:00 P.M. on business days.

FOR FURTHER INFORMATION CONTACT: Richard Stearns, Deputy Chief Counsel,

Enforcement Division, (202) 906-7966, or Karen Osterloh Counsel

(Banking and Finance), Regulations and Legislation Division, (202) 906-

6639, Chief Counsel's Office, Office of Thrift Supervision, 1700 G

Street, NW., Washington DC 20552.

SUPPLEMENTARY INFORMATION:

Background

The Federal financial institutions supervisory agencies (Agencies)

1 and the Department of the Treasury (Treasury) 2 are

responsible for ensuring that financial institutions apprise Federal

law enforcement authorities of any known or suspected violation of a

Federal criminal statute and of any suspicious financial transaction.

Suspicious financial transactions (which will be the subject of

regulations and other guidance to be issued by Treasury) can include

transactions that a savings association or service corporation suspects

involved funds derived from illicit activities, were conducted for the

purpose of hiding or disguising funds from illicit activity, otherwise

violated the money laundering statutes,3 were potentially designed

to evade the reporting or recordkeeping requirements of the Bank

Secrecy Act (the BSA),4 and transactions that the savings

association or service corporation believes were suspicious for any

other reason.

\1\ The Federal financial institutions supervisory agencies are

the OTS, the Office of the Comptroller of the Currency, the Board of

Governors of the Federal Reserve System, the Federal Deposit

Insurance Corporation, and the National Credit Union Administration.

\2\ Through its Financial Crimes Enforcement Network (FinCEN).

\3\ 18 U.S.C. 1956 and 1957.

\4\ 31 U.S.C. 5311 through 5330.

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Fraud, abusive insider transactions, check kiting schemes, money

laundering, and other crimes can pose serious threats to a financial

institution's continued viability and, if unchecked, can undermine the

public confidence in the nation's financial industry. The Agencies and

Federal law enforcement agencies need to receive timely and detailed

information regarding suspected criminal activity to determine whether

investigations, administrative actions, or criminal prosecutions are

warranted.

An interagency Bank Fraud Working Group (BFWG), consisting of

representatives from many Federal agencies, including the Agencies and

law enforcement agencies, was formed in 1984. The BFWG addresses

substantive issues, promotes cooperation among the Agencies and Federal

and State law enforcement agencies, and improves the Federal

government's response to white collar crime in financial institutions.

Today's revisions to this regulation and the reporting requirements are

being made under the auspices of the BFWG.

Suspicious Activity Report

The Agencies have been working on a project to improve the criminal

referral process, to reduce unnecessary reporting burdens on financial

institutions, and to eliminate confusion associated with the current

duplicative reporting of suspicious financial transactions in criminal

referral forms and currency transaction reports (CTRs).

Contemporaneously, Treasury analyzed the need to implement the

procedures for reporting suspicious financial transactions by financial

organizations following the enactment of the Annuzio-Wylie Anti-Money

Laundering Act of 1992. As a result of these reviews, the Agencies and

Treasury approved the development of a new referral process that

includes suspicious financial transaction reporting.

To implement the reporting process, and to reduce unnecessary

burdens associated with these various reporting requirements, the

Agencies and FinCEN developed a new report form for reporting known or

suspected Federal criminal law violations and suspicious financial

transactions. The new form is designated the Suspicious Activity Report

(SAR).5 The SAR is a simplified and shortened version of its

predecessors.

\5\ The reporting requirements contained in the SAR will be

submitted to the Office of Management and Budget for review in

accordance with the Paperwork Reduction Act of 1980 (44 U.S.C.

3504(h)) and the OTS will seek comments on the SAR in a separate

notice.

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The new referral process and the SAR reduce the burden on savings

associations and service corporations for reporting known or suspected

violations and suspicious financial transactions. The agencies

anticipate that the new process will be instituted by October, 1995.

Proposal

The OTS proposes to revise 12 CFR 563.180 by updating and

clarifying the current rule governing the filing of criminal referral

reports, implementing the new SAR, and eliminating current

[[Page 36367]]

confusing and overly burdensome reporting requirements. This action

should improve reporting of known or suspected violations and

suspicious financial transactions relating to Federally insured

financial institutions while providing uniform data for entry into the

new interagency computer database. The OTS expects that each of the

other Agencies will be making substantially similar changes

contemporaneously.

The proposed changes to the current OTS rules are discussed below.

The principal changes include: (1) raising the mandatory reporting

thresholds for criminal offenses, thereby reducing unnecessary

reporting burdens; (2) requiring the filing of only one form with a

single repository, rather than multiple filings to several Federal law

enforcement agencies and the Agencies, thereby further reducing

reporting burdens; and (3) clarifying the criminal referral and

suspicious financial transaction reporting requirements of the Agencies

and Treasury, thereby eliminating duplicative referrals.

Section 563.180(d)(1) Purpose and Scope

The proposal clarifies the scope of the current rule. Under the

proposal, the SAR will replace the various criminal referral forms that

the Agencies currently require institutions to file. The purpose of the

proposed rule is to ensure that savings associations or service

corporations file a SAR when they detect known or suspected violations

of Federal criminal law or suspicious financial transactions.6

\6\ As noted above, there has been some confusion regarding

filing of criminal referrals and CTRs for suspicious cash

transactions. The BSA requires all financial institutions to file

CTRs in accordance with Treasury's implementing regulations (31 CFR

part 103). Part 103 requires financial institutions to file a CTR

whenever a currency transaction exceeds $10,000. If a currency

transaction exceeds $10,000 and is suspicious, the institution,

under these new requirements, will file both a CTR (reporting the

currency transaction) and a SAR (reporting the suspicious criminal

aspect of the transaction). If a currency transaction equals or is

below $10,000 but is suspicious, the institution will only file a

SAR.

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The proposed rule continues to require reporting by savings

associations and by service corporations. It does not, however, impose

a separate reporting obligation on operating subsidiaries established

by savings associations. OTS regulations provide that all Federal laws

and regulations governing the operation of savings associations apply

to operating subsidiaries, unless otherwise provided by statute,

regulations or policies of the OTS. The OTS general policy is to

consolidate regulatory requirements for the operating subsidiary with

the parent. Accordingly, the reporting obligation of parent savings

associations under Sec. 563.180 will be deemed to include the duty to

report events or conduct occurring at the operating subsidiary level,

as well as the parent level.

Under the current regulation, savings association holding companies

are not required to file reports. Holding companies are encouraged to

do so when actions have a substantial impact on the depository

institutions that they own. The OTS solicits comment on whether to

amend the rule so that it expressly requires savings association

holding companies to file SARs regarding known or suspected criminal

violations or suspicious financial transactions that affect their

depository institution subsidiaries.

Section 563.180(d)(2) Definitions

Proposed Sec. 563.180(d)(2) defines the following terms:

``FinCEN,'' ``institution-affiliated party,'' ``instructions,'' ``known

or suspected violation,'' and ``SAR.'' The definitions should make the

rule easier to interpret and apply.

In particular, the definition of ``known or suspected violation''

refers to any matter for which a savings association or service

corporation has a basis to believe that a violation of any Federal

criminal statute (including a pattern of criminal violations) has

occurred or has been attempted, is occurring, or may occur, coupled

with a basis to believe that a savings association or service

corporation was an actual or potential victim of the criminal violation

or was involved in or was used to facilitate the criminal violation.

This definition supplants the definition of suspected crimes, the

illustrative listing of crimes requiring reporting, and other

descriptions of known or suspected crimes in the existing rule at 12

CFR 563.180(d) (1) and (2) (1995).

Section 563.180(d)(3) Reports Required

The proposal clarifies the categories of violations that are

subject to the reporting obligation. In addition, the proposal reduces

the regulatory burden on savings associations and service corporations

by increasing applicable dollar thresholds for two categories of

violations, and by eliminating the requirement for duplicative filings

with multiple Federal agencies.

Proposed Sec. 563.180(d)(3)(i) requires a savings association or

service corporation to file a SAR, regardless of the dollar amount

involved, whenever it has a substantial basis for believing that a

director, officer, employee, agent or other institution-affiliated

party (as defined in the regulation, which cross references section

3(u) of the FDIA) committed or aided in the commission of a Federal

crime. This provision is substantially identical to the existing rule

at 12 CFR 563.180(d)(1)(i)(1995), with one exception. The existing rule

applies to violations involving ``affiliated parties,'' as defined in

12 CFR 561.5(1995). Unfortunately, the cited definition is both too

narrow and too broad. For example, ``affiliated persons'' under 12 CFR

561.5 does not include all shareholders who may participate in the

conduct of the affairs of the institution, but does include members of

a director's or officer's immediate family who have no connection to

the institution. The OTS believes that the proposed rule describes

relevant insiders with greater precision.

OTS's current rules further require savings associations and

service corporations to report known or suspected criminal acts that

involve actual or anticipated losses of: (1) $1,000 or more where there

is a basis for identifying a non-insider suspect; or (2) $5,000 or more

regardless of whether a suspect has been identified.7 The proposed

rule at Secs. 563.180(d)(3) (ii) and (iii) would reduce this reporting

burden by increasing the $1,000 and $5,000 thresholds to $5,000 and

$25,000, respectively. Moreover, the proposed rule clarifies that

threshold amounts are based on actual or potential losses to the

savings association or service corporation, without regard to possible

reimbursement or recovery.

\7\ 12 CFR 563.180(d)(1) (ii) and (iii) (1995).

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Proposed Sec. 563.180(d)(3)(iv) requires a savings association or

service corporation to report any financial transaction, regardless of

the dollar amount if: (1) the institution suspects the transaction

involved funds derived from illicit activity, was conducted for the

purpose of hiding or disguising funds from illicit activity, or in any

way violated the money laundering statutes; 8 (2) the institution

suspects the transaction was potentially designed to evade the

reporting or recordkeeping requirements of the BSA; 9 or (3) the

institution believes the transaction to be suspicious for any reason.

This revision makes minor clarifying changes to the existing

requirements at 12 CFR 563.180(d)(1)(iv) (1995).

\8\ 18 U.S.C. 1956 and 1957.

\9\ 31 U.S.C. 5311 through 5330.

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The current rules require savings associations and service

corporations to file a criminal referral report with

[[Page 36368]]

appropriate Federal law enforcement authorities. Because this process

results in multiple filings with several agencies, the Agencies propose

to reduce the filing burden by permitting institutions to file a single

SAR at one location. Accordingly, under proposed Sec. 563.180(d)(3), a

savings association or service corporation will file a SAR with all

appropriate Federal law enforcement agencies by sending a single copy

of the SAR to the FinCEN, whose address will be printed on the SAR.

FinCEN will input the information contained on the SARs into a

newly created database that FinCEN will maintain. This process will

fulfill the regulatory requirement that a savings association or

service corporation refer any known or suspected criminal violation to

appropriate Federal law enforcement agencies. The database will enhance

Federal law enforcement and supervisory agencies' ability to track,

investigate and prosecute individuals suspected of violating Federal

criminal law. This change will ensure that all SARs are placed in the

database at FinCEN and that the information is made available on

computer to the appropriate law enforcement and supervisory agencies as

quickly as possible.

To further reduce the reporting burden, the Agencies are modifying

the manner in which financial institutions file a SAR. In following the

Instructions on a SAR, a savings association or service corporation may

file the referral form in several ways, including submitting an

original form or a photocopy, and filing a SAR by magnetic means, such

as by a computer disk.10 In the future, the OTS and the other

Agencies anticipate that a financial institution will be able to file a

SAR electronically.

\10\ FinCEN, however, will not be able to receive SARs by

facsimile machine.

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The Agencies, working with FinCEN, are developing computer software

to assist financial institutions in preparing and filing SARs. The

software will allow an institution to complete a SAR, to save the SAR

on its computers, and to print a hard copy of the SAR for its own

records. The computer software will also enable an institution to file

a SAR using various forms of magnetic media, such as computer disk or

magnetic tape. The OTS will make the software available to all savings

associations and service corporations. A savings association or service

corporation, of course, may complete and file a SAR using printed forms

without using this software, if it so desires. The Instructions to the

SAR will address new permissible filing methods as the methods are

developed.

Section 563.180(d)(4) Service Corporations

When a service corporation must file a report under the current

rule, the required filing may be made either by the service corporation

or by a saving association that wholly or partially owns the service

corporation. This provision is retained in the proposed rule at 12 CFR

563.180(d)(4).

Section 563.180(d)(5) Time for Reporting

Proposed Sec. 563.180(d)(5) requires a savings association or

service corporation to file the SAR within 30 calendar days after the

date of detection of the act triggering the reporting requirement. If

no suspect is identified on that date, the savings association or

service corporation may delay the filing of a SAR for an additional 30

calendar days after the identification of a suspect. Filings, however,

may not be delayed for more than 60 calendar days after detection. The

proposal substantially modifies the current regulation at

Sec. 563.180(d)(2) which requires the savings association or service

corporation to file within 14 business days after discovery of the

activity.

Section 563.180(d)(6) Reports to State and Local Authorities

The proposed rule includes a new provision encouraging savings

associations and service corporations to file SARs with State and local

law enforcement agencies where appropriate.

Section 563.180(d)(7) Retention of Records

Existing OTS rules require savings associations and service

corporations to retain a copy of the criminal referral report and

related records for a period of ten years.11 This requirement is

retained in the proposed rules at Sec. 563.180(d)(7).

\11\ 12 CFR 563.180(d)(5) (1995). This time frame corresponds

with the statute of limitations for most Federal criminal statutes

involving financial institutions.

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The current instructions to the criminal referral form require

savings associations and service corporations to submit copies of all

related documentation when a criminal referral is filed. The new SAR

reduces the regulatory burdens on the industry by eliminating this

requirement altogether. Instead, the proposal requires that the

documentation be identified and treated as filed with the SAR and that

the savings association or service corporation maintain the

documentation, along with a copy of the SAR, for ten years from the

submission date. This approach ensures that Federal law enforcement

agencies and the Agencies, upon request, have access to any

documentation necessary to prosecute a violation or pursue

administrative action by requiring the preservation of the underlying

documentation for ten years.

Section 563.180(d)(8) Exemptions

The proposed rule would exempt robberies and burglaries and

attempted robberies and burglaries that are reported to the appropriate

local law enforcement authorities. This exemption is substantially

similar to the existing exemption at 12 CFR 563.180(d)(2)(1995).

Section 563.180(d)(9) Notification of the Board of Directors

Proposed Sec. 563.180(d)(9) requires the management of a savings

association to promptly notify the board of directors (or a committee

of directors or executive officers designated by the board to receive

notice) whenever the savings association or a service corporation in

which the savings association has an ownership interest has filed a

SAR. Where an executive officer or director is a suspect, the proposal

requires management to notify the entire board of directors, except the

suspect.

This proposed rule generally incorporates the requirements of the

existing rules at Sec. 563.180(d)(4) (1995), but includes several

modifications designed to provide savings associations with greater

flexibility. These modifications: (1) permit notification to a

designated committee in lieu of the entire board; (2) require

``prompt'' notification, rather than notification at the first

regularly scheduled board meeting after the filing of the SAR; and (3)

assign notification responsibility to management of the savings

association rather than the chief executive officer. The OTS expects

each savings association to maintain appropriate mechanisms to ensure

that the board of directors will be informed promptly of SAR filings.

Section 563.180(d)(10) Compliance

The proposed rule includes a new provision stating that the failure

to file a SAR in accordance with the regulation and the Instructions

may result in supervisory actions, including enforcement actions.

[[Page 36369]]

Section 563.180(d)(11) Obtaining the SAR

Proposed Sec. 563.180(d)(11) states that savings associations and

service corporations may obtain the SAR form from the appropriate OTS

Regional Office at the address listed in 12 CFR 516.1(b) (1995). The

current rule does not contain a comparable instruction.

Section 563.180(d)(12) Confidentiality of SARs

The proposed rule contains a new provision preserving the

confidentiality of SARs and the information contained in SARs.

Comments

The OTS invites public comment on all aspects of this proposal.

Regulatory Flexibility Act

Pursuant to section 605(b) of the Regulatory Flexibility Act, the

OTS hereby certifies that this proposed rule will not have a

significant economic impact on a substantial number of small entities.

This proposal primarily reorganizes the process for reporting crimes

and suspicious activities and has no material impact on savings

associations and service corporations, regardless of size. Accordingly,

a regulatory flexibility analysis is not required.

Executive Order 12866

The OTS has determined that this document is not a significant

regulatory action under Executive Order 12866.

Unfunded Mandates Reform Act of 1995

Section 202 of the Unfunded Mandates Reform Act of 1995, Pub. L.

104-4 (signed into law on March 22, 1995) requires that an agency

prepare a budgetary impact statement before promulgating a rule that

includes a Federal mandate that may result in expenditure by State,

local, and tribal governments, in the aggregate, or by the private

sector of $100 million or more in one year. If the budgetary impact

statement is required, section 205 of the Act also requires an agency

to identify and consider a reasonable number of regulatory alternatives

before promulgating a rule. This proposal reorganizes the process for

reporting crimes and suspicious activities by savings associations and

service corporations to Federal agencies. The OTS has determined that

the final rule will not result in expenditure by State, local, or

tribal governments or by the private sector of more than $100 million.

Accordingly, the Unfunded Mandates Reform Act does not apply.

List of Subjects in 12 CFR Part 563

Accounting, Advertising, Crime, Currency, Flood insurance,

Investments, Reporting and recordkeeping requirements, Savings

associations, Securities, Surety bonds.

Authority and Issuance

For the reasons set out in the preamble, part 563 of chapter V of

title 12 of the Code of Federal Regulations is proposed to be amended

as set forth below:

SUBCHAPTER D--REGULATIONS APPLICABLE TO ALL SAVINGS ASSOCIATIONS

PART 563--OPERATIONS

1. The authority citation for part 563 continues to read as

follows:

Authority: 12 U.S.C. 375b, 1462, 1462a, 1463, 1464, 1467a, 1468,

1817, 1828, 3806; 42 U.S.C. 4012a, 4104a, 4104b, 4106, 4128.

2. Section 563.180 is amended by revising the section heading and

paragraph (d) to read as follows:

Sec. 563.180 Suspicious Activity Reports and other reports and

statements.

* * * * *

(d) Suspicious Activity Reports.--(1) Purpose and scope. This

paragraph (d) ensures that savings associations and service

corporations file a Suspicious Activity Report when they detect a known

or suspected violation or a suspicious transaction.

(2) Definitions. For the purposes of this paragraph (d):

(i) FinCEN means the Financial Crimes Enforcement Network of the

Department of the Treasury.

(ii) Institution-affiliated party means any institution-affiliated

party as that term is defined in sections 3(u) and 8(b)(8) of the

Federal Deposit Insurance Act (12 U.S.C. 1813(u) and 1818(b)(8)).

(iii) Instructions means the instructions on the SAR.

(iv) Known or suspected violation means any matter for which there

is a basis to believe that a violation of a Federal criminal statute

(including a pattern of criminal violations) has occurred or has been

attempted, is occurring, or may occur, and there is a basis to believe

that a savings association or service corporation was an actual or

potential victim of the criminal violation or was involved in or was

used to facilitate the criminal violation.

(v) SAR means a Suspicious Activity Report.

(3) SARs required. A savings association or service corporation

shall file a SAR with the appropriate Federal law enforcement agencies

and the Department of the Treasury, in accordance with the

Instructions, by sending a completed SAR to FinCEN, in the following

circumstances:

(i) Whenever the savings association or service corporation detects

a known or suspected violation of Federal criminal law and has a

substantial basis to believe that one of its directors, officers,

employees, agents, or other institution-affiliated parties committed or

aided in the commission of the violation;

(ii) Whenever the savings association or service corporation

detects a known or suspected violation of Federal criminal law, there

is an actual or potential loss to the savings association or service

corporation (before reimbursement or recovery) aggregating $5,000 or

more, and the savings association or service corporation has a

substantial basis for identifying a possible suspect or group of

suspects, where none of the suspects are included in paragraph

(d)(3)(i) of this section;

(iii) Whenever the savings association or service corporation

detects a known or suspected violation of Federal criminal law, there

is an actual or potential loss to the savings association or service

corporation (before reimbursement or recovery) aggregating $25,000 or

more, and the savings association or service corporation has no

substantial basis for identifying a possible suspect or group of

suspects; or

(iv) Whenever a financial transaction is conducted, or attempted,

at the savings association or service corporation and:

(A) The savings association or service corporation suspects that

the transaction involved funds derived from illicit activity, was

conducted for the purpose of hiding or disguising funds from illicit

activity, or in any way violated the money laundering statutes (18

U.S.C. 1956 and 1957);

(B) The savings association or service corporation suspects that

the transaction was potentially designed to evade the reporting or

recordkeeping requirements of the Bank Secrecy Act (31 U.S.C. 5311

through 5330) or regulations issued thereunder; or

(C) The savings association or service corporation believes that

the transaction was suspicious for any reason.

(4) Service corporations. When a service corporation is required to

file a SAR under paragraph (d)(3) of this section, either the service

corporation or a savings association that wholly or partially owns the

service corporation, may file the SAR.

(5) Time for reporting.--(i) Generally. A savings association or

service corporation shall file the SAR required

[[Page 36370]]

by paragraph (d)(3) of this section within 30 calendar days after the

date of initial detection of an act described in paragraph (d)(3) of

this section. In situations involving violations that require immediate

attention, such as when a reportable violation is on-going, the savings

association or service corporation shall immediately notify, by

telephone, the appropriate law enforcement authority in addition to

filing a timely SAR.

(ii) No suspect identified. If no suspect was identified on the

date of detection of an act described in paragraph (d)(3) of this

section, the savings association or service corporation may delay

filing the SAR for an additional 30 calendar days after the

identification of a suspect, but in no case may savings association or

service corporation delay filing a SAR for more than 60 calendar days

after the date of detection of an act described in paragraph (d)(3) of

this section.

(6) Reports to State and local authorities. A savings association

or service corporation is encouraged to file a copy of the SAR with

State and local law enforcement agencies where appropriate.

(7) Retention of records. A savings association or service

corporation shall maintain a copy of any SAR filed and the original of

any related documentation for a period of ten years from the date of

filing the SAR, unless the OTS informs the savings association or

service corporation in writing that it may discard the materials

sooner. A savings association or service corporation must make all

supporting documentation available to appropriate law enforcement

agencies upon request. Supporting documentation shall be identified and

treated as filed with the SAR.

(8) Exemptions. A savings association or service corporation need

not file a SAR for a robbery or burglary committed or attempted that is

reported to appropriate law enforcement authorities.

(9) Notification to board of directors.--(i) Generally. Whenever a

savings association (or a service corporation in which the savings

association has an ownership interest) files a SAR pursuant to this

paragraph (d), the management of the savings association shall promptly

notify its board of directors or a committee of directors or executive

officers designated by the board of directors to receive such notice.

(ii) Suspect is a director or officer. If the savings association

or service corporation files a SAR pursuant to paragraph (d)(3) of this

section and the suspect is a director or executive officer of the

savings association, the savings association must not notify the

suspect in accordance with 31 U.S.C. 5318, but must notify all

directors who are not suspects.

(10) Compliance. Failure to file a SAR in accordance with this

paragraph (d) and the Instructions may subject the savings association

or service corporation, its directors, officers, employees, agents, or

other institution-affiliated parties to supervisory actions including

enforcement actions.

(11) Obtaining SARs. A savings association or service corporation

may obtain SARs and the Instructions from the appropriate OTS Regional

Office listed in 12 CFR 516.1(b).

(12) Confidentiality of SARs. SARs are confidential. Any person

subpoenaed or otherwise requested to disclose a SAR or the information

contained in a SAR shall decline to produce the information citing

these regulations, applicable law (e.g., 31 U.S.C. 5318(g)), or both.

* * * * *

Dated: July 12, 1995.

By the Office of Thrift Supervision.

Jonathan L. Fiechter,

Acting Director.

[FR Doc. 95-17485 Filed 7-14-95; 8:45 am]

BILLING CODE 6720-01-P