To embed, copy and paste the code into your website or blog: The Commission periodically has filed enforcement actions against broker-dealers for failing to file SARs – suspicious activity reports -- typically centered on a failure to file reports regarding microcap issuers. Those actions are based on Exchange Act Section 17(a) and Rule 17a-8. SARs on the other hand trace to the Bank Secrecy Act and FinCEN. The question of broker-dealer compliance with SARs and the Commission’s authority under the Exchange Act Section and Rule typically cited by the agency was raised in an action recently decided by the Second Circuit Court of Appeals.