4.26.3  Role of WISDM

Manual Transmittal

March 15, 2013

Purpose

(1) This transmits revised text for IRM 4.26.3, Bank Secrecy Act, Role of Workload Identification, Selection, Delivery, and Monitoring (WISDM).

Material Changes

(1) The title has been revised to reflect that responsibility for the section contents resides in BSA WISDM.

(2) The text has been revised and updated throughout to describe the role of BSA WISDM.

(3) Citations from 31 CFR Part 103 were renumbered to 31 CFR Chapter X, effective March 1, 2011.

(4) BSA Policy Memo dated June 17, 2008 has been added as Exhibit 4.26.3-1.

(5) Various WISDM forms are added as exhibits.

Effect on Other Documents

This supersedes IRM 4.26.3 dated December 12, 2006.

Audience

Intended audience is employees of the Bank Secrecy Act Program in the Small Business/Self Employed (SB/SE) division and can be referenced by all field compliance personnel.

Effective Date

(03-15-2013)

William P. Marshall
Director, Fraud/BSA
Small Business/Self-Employed

4.26.3.1  (03-15-2013)
Overview

  1. This section describes the role of BSA WISDM (Workload Identification, Selection, Delivery, and Monitoring).

  2. WISDM is responsible for coordinating, monitoring, and reporting the activities of the Title 31 and Form 8300 examination programs.

4.26.3.2  (03-15-2013)
WISDM Responsibilities

  1. WISDM is responsible for:

    1. Identifying non-bank financial institutions (NBFIs) under IRS jurisdiction subject to the BSA under Title 31 (31 CFR Chapter X; formerly 31 CFR Part 103) and non-financial trades and businesses (NFTBs) subject to Form 8300 requirements under Title 26 (IRC 6050I) or Title 31 (31 USC 5331);

    2. Ensuring Criminal Investigation (CI) does not have jurisdiction over selected NBFIs or NFTBs;

    3. Notifying identified money services businesses (MSBs) of BSA recordkeeping and reporting requirements using Letter 1052;

    4. Title 31 Database maintenance;

    5. Building case files for selected workload;

    6. Assigning the initial grade of case using the case assignment guidelines;

      Note:

      Final case grade is determined by the field group manager upon receipt and review of case.

    7. Coordinating, monitoring, and reporting the results of Title 31 and Form 8300 examinations and compliance activities;

    8. Acting as the contact point for technical or procedural questions and problems related to the Title 31 database and the ERCS system;

    9. Providing management information and inventory reports;

    10. Coordinating special programs, projects, centralized examinations, and specialized industry examinations for both Title 31 and Form 8300;

    11. Coordinating with the operating divisions to ensure the accuracy of data, as well as proper customer contact and coordination;

    12. Preparing the annual BSA work plan, including Form 8300, BSA Territories, and Grade 13 work; and

    13. Selecting BSA and Form 8300 workload for BSA examiners using a risk-based approach.

  2. Selection factors used in a risk-based approach include:

    • Tips from law enforcement or other regulatory agencies

    • Location in High Intensity Drug Trafficking Areas (HIDTAs) and High Intensity Financial Crimes Areas (HIFCAs)

    • Unusual filing patterns noted on Currency Transaction Report (CTR) and/or Suspicious Activity Report (SAR) filings

    • Status as an MSB principal (versus an agent)

    • Issues identified in previous examinations of the entity

    • Entities with an inadequate anti-money laundering (AML) compliance program

    • Priority status, as identified in the BSA Program Letter

4.26.3.2.1  (03-15-2013)
Identification of BSA Entities

  1. WISDM identifies entities for examination over which IRS has BSA jurisdiction. Most entities under IRS jurisdiction are commonly referred to as NBFIs. IRS also has delegated examination authority to ensure BSA compliance over all financial institutions not regulated by a Federal bank supervisory agency; a Federal securities agency; a Federal commodities agency; or a self-regulatory organization, registered with a Federal securities agency or a Federal commodities agency. NBFIs currently include:

    1. MSBs, subject to certain transaction thresholds;

    2. Casinos and card clubs (including Indian tribal casinos);

    3. Credit unions that are state chartered and non-Federally insured;

    4. Insurance companies subject to the AML compliance program requirements of the BSA; and

    5. Dealers in precious metals, precious stones, or jewels subject to the AML compliance program requirements of the BSA.

      Note:

      This list will grow as other future classes of BSA entities are defined and jurisdiction is delegated to IRS by the Financial Crimes Enforcement Network (FinCEN).

  2. MSBs, subject to certain threshold amounts under IRS jurisdiction include:

    1. Dealers in Foreign Exchange

    2. Check Cashers

    3. Issuers or Sellers of Traveler's Checks or Money Orders

    4. Providers of Prepaid Access

    5. Sellers of Prepaid Access

    6. Money Transmitters.

  3. The following sources may be used to identify NBFIs:

    1. External databases

    2. Field referrals (referrals may require a related statute determination)

    3. BSA examiner referrals resulting from physical observation or review of competitor listings

    4. Telephone books

    5. Web Currency and Banking Retrieval System (WebCBRS)

    6. Neighborhood publications

    7. Trade or Business Associations

    8. Office of Research and Analysis

    9. Enterprise Computing Center-Detroit (ECC-DET) special reports

    10. The Internet

    11. State and local licensing and/or regulatory agencies

    12. CI referrals

    13. MSB agent lists received from examiners and FinCEN

    14. Referrals from FinCEN

    15. Referrals from Federal, state, or local law enforcement agencies.

  4. The Integrated Data Retrieval System (IDRS) or other tax-based systems may not be used to locate information for BSA purposes.

  5. When a new NBFI entity is identified, the entity is added to the Title 31 database.

  6. WebCBRS is one of the most effective tools in BSA compliance efforts. For more information on WebCBRS and the program coordinator’s use of WebCBRS, refer to IRM 4.26.4.

4.26.3.2.1.1  (03-15-2013)
Notification After Identification

  1. Notification of the BSA reporting and recordkeeping requirements for MSBs, casinos, and credit unions is accomplished by issuance of Form Letter 1052 and the required attachment. See Letter 1052.

  2. For MSBs, the Letter 1052 must include as an attachment a copy of the FinCEN publication "Money Laundering Prevention, A Money Services Business Guide." Orders for this free publication should be placed online at the FinCEN web site: http://www.fincen.gov/financial_institutions/msb/materials/html

  3. The requirement to furnish a copy of the current regulations (31 CFR Chapter X) to NBFIs that are not MSBs, e.g., casinos and credit unions, continues until FinCEN publishes further industry-specific guidance.

  4. The date Letter 1052 was issued must be documented in the case file and on the Title 31 database.

  5. A copy of Letter 1052 must be retained in the case file.

4.26.3.2.2  (03-15-2013)
Identification of Form 8300 Entities

  1. WISDM is responsible for identifying for examination, trades or businesses that may conduct transactions in which they receive in excess of $10,000 in cash and have a requirement to file Form 8300. Resources that can be used to identify trades or businesses include:

    1. Classified section of the phone book and the business-to-business phone book

    2. Realtors’ listings

    3. Leads from CI

    4. The WebCBRS

    5. State law enforcement agency data

    6. Information from other examinations

    7. Internal and external databases

    8. Examiner referrals through physical observation and during an interview (BSA New Entity / Competitor Form)

    9. Neighborhood publications

    10. Listings from the Office of Research and Analysis

    11. Enterprise Computing Center-Detroit (ECC-DET) special reports

    12. Newspapers, magazines, or other periodicals

    13. The Internet

    14. The Compliance Data Warehouse/North American Industry Classification Code (CDW/NAICS) Database.

  2. WebCBRS is one of the most effective tools in our compliance efforts. For more information on WebCBRS and the uses of WebCBRS, refer to IRM 4.26.4.

4.26.3.2.3  (03-15-2013)
Title 31 Database Maintenance

  1. WISDM is responsible for maintenance of the Title 31 Database.

  2. WISDM can accurately respond to management inquiries and complete management information reports if the database is updated properly and timely.

  3. WISDM is the contact point for questions regarding the database.

  4. The BSA coordinator is responsible for ensuring the information in the Title 31 Database is properly updated.

4.26.3.2.4  (03-15-2013)
Title 31 Case Selection For Assignment

  1. The BSA coordinator selects entities for Title 31 examinations, in conjunction with the BSA Program Letter, using risk-based analysis to identify entities with the highest potential noncompliance for examination, such as:

    1. Entities in local geographic areas identified as HIDTAs and HIFCAs

    2. Entities with a previous history of non-compliance

    3. Entities with unusual CTR/SAR filing patterns

    4. Anomalies in bank CTRs/SARs filed on the entity, indicating unusual cash activity

    5. Entities not registered as MSBs but appear to be operating as MSBs

    6. Entities that are MSBs that have not re-registered or renewed their registration

    7. Entities with a history of filing forms late and/or with errors

    8. Entities with appearance of facilitating structuring

    9. Entities identified through referrals from CI, FinCEN, or other BSA examinations

    10. Entities referred by Federal, state, or local law enforcement agencies or a regulatory agency

  2. Cases involving the insurance industry or dealers in precious metals, precious stones, and jewels will be selected for Title 31 examinations and not initially selected for Form 8300 examinations.

  3. When selecting NBFIs for examination, the BSA coordinator should consider the priorities in the current BSA Program Letter, the annual work plan, available resources, case grading guidelines, balanced coverage (geographic area and industry), and anticipated field inventory needs.

  4. The BSA coordinator analyzes current inventory levels of field groups to ensure the steady flow and adequate assignment of cases.

  5. Input from FinCEN and the operating divisions (e.g., TE/GE or CI) can assist the coordinator in assessing risk.

  6. Prior to assigning cases to the BSA groups, selected entities must be forwarded to CI for clearance.

  7. The BSA coordinator provides BSA field groups with the administrative case file for the selected entity. The administrative case file will include the following items as part of the case building process:

    1. The Examining Officer’s Activity Record/WISDM Case Building Check List showing the date entity was selected, date CI clearance was requested and received, date the L-1052 was mailed, dates of WebCBRS and internet research, date the entity was called and verified to be in business, date case grading and classification was performed, and date when case was forwarded to BSA group. Also includes other pertinent information such as financial services offered and name of owner.

      Note:

      WISDM Case Building Check List is an optional document which may be used in lieu of activity record. Exhibit 4.26.3-2.

    2. The BSA Title 31 Case Grading Sheet. Exhibit 4.26.3-3.

      Note:

      WISDM Coordinators use the case grading sheet to determine the initial grade of case; however, it is the group manager's responsibility to determine the actual case grade after review (e.g., initial assignment, GMCM, case closure, etc.).

    3. The BSA Title 31 Case Classification Sheet. Exhibit 4.26.3-4

      Note:

      Use of this form is optional. In lieu of this document, an activity record can be used to notate required information.

    4. Current WebCBRS data research.

    5. Any confidential WebCBRS information, such as SAR data, must be protected in a sealed confidential envelope.

    6. Other information to confirm address and business type, e.g., information from Accurint.

    7. Copy of Letter 1052.

    8. Copy of prior Letter 1112, if applicable.

    9. Closing Document.

  8. The WISDM Title 31 Casebuilding Procedures memorandum is shown in Exhibit 4.26.3-5.

  9. The selected case files are sent to the BSA group, accompanied by Form 3210, Document Transmittal.

4.26.3.2.5  (03-15-2013)
Form 8300 Case Selection for Assignment

  1. The BSA coordinator should select entities for Form 8300 examinations using risk-based analysis to identify entities with highest potential for noncompliance such as:

    1. Entities currently filing income tax returns and/or employment tax returns with no financial information on WebCBRS (if entity is a cash-intensive business)

    2. Entities in local geographic areas with high potential for money laundering such as HIDTAs and HIFCAs

    3. Entities with a previous history of noncompliance

    4. Entities cited for poor or inadequate recordkeeping

    5. Entities with unusual Form 8300 and CTR filing patterns

    6. Entities referred by Federal, state, or local law enforcement agencies or a regulatory agency

    7. Entities with gross revenue disproportionate to Form 8300 and CTR filings

    8. Anomalies in bank CTR/SARs filed on the entity

    9. Entities identified through other BSA examinations, e.g., during a centralized examination of another entity

  2. When selecting NFTBs for examination, the BSA coordinator should consider the priorities outlined in the current BSA Program Letter, the annual work plan, available resources, case grading guidelines, balanced coverage (geographic area and industry), and anticipated field inventory needs.

  3. The BSA coordinator will analyze current inventory levels of field groups to ensure the steady flow and adequate assignment of cases.

  4. Input from FinCEN and the operating divisions (i.e., TEGE or CI) can assist the coordinator in assessing risk.

  5. Prior to assigning cases to the BSA groups, the BSA coordinator will ensure the entities are not controlled by CI.

  6. The BSA coordinator will provide the examiner with the administrative case file for the selected entity. The administrative case file will include the following items as part of the case building process:

    1. Case Activity Record documented to reflect dates and actions taken

    2. IDRS research

      Note:

      See IDRS Instructions for Form 8300 in Exhibit 4.26.3-6.

    3. WebCBRS research – Form 8300s, CTRs, SARs (SAR information is protected in secure and confidential envelope)

    4. Other information to confirm address and business type – for example web page print, yellow page information

    5. Form 8300 Case Grading Sheet. Exhibit 4.26.3-7.

      Note:

      WISDM coordinators will utilize the case grading sheet to determine the initial grade of a case; however, it will be the field group manager's responsibility to determine the actual case grade after review, e.g., initial assignment, GMCM, case closure, etc.

    6. Form 8300 Case Classification Sheet is optional. In lieu of this document, an activity record can be used to notate required information. Exhibit 4.26.3-8.

  7. Form 8300 examinations under IRC 6050I must be controlled on ERCS. See ERCS Instructions in Exhibit 4.26.3-9.

  8. Form 8300 casebuilding instructions are found in Exhibit 4.26.3-10. Form 8300 case file assembly instructions are found in Exhibit 4.26.3-11.

  9. The selected case files will be sent to the BSA group, accompanied by Form 3210.

4.26.3.2.6  (03-15-2013)
WISDM Screening of Closed Case Data

  1. WISDM monitors closed case data for accuracy.

  2. WISDM uses that data for monitoring and reports.

4.26.3.2.7  (03-15-2013)
BSA Information Leads

  1. During the course of a BSA examination, information may be uncovered pertaining to the financial transactions of individuals and businesses. This information may have a material impact on Title 26 IRC compliance. The BSA field group is responsible for preparing Form 5346, Examination Information Report, for referral of the information.

  2. The BSA field groups will forward the income tax or employment tax leads on Form 5346 to WISDM. Leads deemed worthy for referral to CI must be made on Form 3949, Information Report Referral, and also forwarded to WISDM.

  3. Lead Development Center (LDC) referrals must be completed on Form 14242, Reporting Abusive Tax Promotions and/or Promoters, and mailed or faxed directly to the LDC with a copy forwarded to WISDM.

  4. WISDM will research and screen the referrals and forward the referrals to the appropriate IRS operating division.

  5. All information reports (Forms 5346, 3949, and 14242) sent to WISDM are tracked, monitored, and reported.

4.26.3.2.7.1  (03-15-2013)
Using Referrals in Title 31 and Form 8300

  1. Referrals may be received from FinCEN, SAR Review Teams, CI groups, BSA groups, among other sources, in regard to the activity of an NBFI or an NFTB. SAR information may be included in the case file, if protected in a secure and confidential envelope, for both Title 31 and Form 8300 cases.

  2. The BSA coordinator will exercise independent judgment on the appropriate BSA action to take on referrals received. Any action, such as assigning the case for a BSA or Form 8300 examination, is to be based on the same criteria used to select any other BSA work.

  3. When the information source is a SAR, the responsibility for the security and use of the SAR and the SAR data is with each person having access. The information is sensitive and must be treated accordingly. The information may be used only for a purpose related to a criminal, tax, or regulatory investigation or proceeding, or in the conduct of intelligence or counterintelligence activities to protect against international terrorism.

  4. The information contained in a SAR cannot be further released, disseminated, disclosed, or transmitted without prior approval of the Director of FinCEN or his authorized delegate. No SAR information, including the existence of a SAR, may be disclosed in the course of any BSA activity to the examined entity or to any other person or entity outside the IRS. A SAR filed under the BSA must be treated with particular care given the unsubstantiated allegations of possible criminal activity it contains, akin to allegations contained in confidential informant tips. Such reports, or the fact they have been filed, may not be disclosed by a government employee to any person involved in the transaction, "other than as necessary to fulfill the official duties of such officer or employee." 31 USC 5318 (g)(2)(ii). Unauthorized release of information collected under the BSA may result in criminal or civil sanctions. SAR information is extremely sensitive data.

  5. Since disclosing SAR information would identify a confidential informant and would seriously impair a civil or criminal investigation, use of a SAR-based lead in Title 31 or Form 8300 activities is restricted in the same manner as its use in any examination. (See IRM 4.26.14.) The examiner is prohibited from doing the following:

    • Disclosing to anyone outside the IRS that a SAR has been filed;

    • Proposing a reporting violation based solely on information contained in a SAR, CI referral, or other referral;

    • Disclosing a source or possible source of the information; and

    • Conducting the examination in a manner in which the trade or business could reasonably conclude any of the above.

  6. Civil and criminal penalties may apply with respect to the unauthorized disclosure of SARs. Such disclosures undermine the very purpose for which the suspicious activity reporting system was created - the protection of the nation's financial system through the prevention, detection, and prosecution of financial crimes and terrorist financing. The unauthorized disclosure of SARs can compromise the national security of the United States and threaten the safety and security of those institutions and individuals who file such reports. An unauthorized disclosure of SAR information is a very serious matter. All such unauthorized disclosures by IRS personnel are investigated. The IRS is committed to continuing to work with FinCEN, the Federal functional regulatory agencies, law enforcement, and the financial services industry to ensure that the information contained in SARs is safeguarded.

  7. SARs, like all reports filed under the BSA, are exempt from the disclosure provisions of 5 USC 552, Freedom of Information Act (FOIA).

4.26.3.2.8  (03-15-2013)
Administrative Procedures

  1. WISDM is responsible for monitoring and reporting on all BSA program activities, including:

    1. Maintaining BSA inventory on the Title 31 database;

    2. Establishing and maintaining Form 8300 cases examined under IRC 6050I on ERCS;

    3. Preparing reports;

    4. Shipping historical case files to ECC-DET, as appropriate;

    5. Assisting with development and delivery of training;

    6. Responding to requests from management;

    7. Coordinating with operating divisions, and local, state, and Federal agencies; and

    8. Physical control of unassigned BSA inventory.

  2. For Title 31 project codes, see Exhibit 4.26.3-12. For Title 31 freeze and reason codes, see Exhibit 4.26.3-13.

  3. The BSA coordinator will establish the initial year of a Form 8300 examination under IRC 6050I on ERCS as:

    1. For administrative case files: MFT A2 and Activity Code: 509

    2. For penalty case files: MFT P9 and Activity Code 506

    3. Source Code: 99

    4. Primary Business Code: 217

    5. Secondary Business Code (SBC): 87700

    6. Employee Group Code (EGC): 1887 or 2887

    7. SB/SE POD code of the entity

    8. Status 08

    9. Tax Period: case is established as calendar year (calendar year is always year prior to current year), as per BSA Policy Memo of July 17, 2008. See Exhibit 4.26.3-1.

    10. Tracking Code: see the BSA SharePoint site and then select "Forms" under "WISDM Documents" for the most current tracking codes. Exhibit 4.26.3-14.

    11. With the exception of the activity code, the A2 record must exactly match the P9 record.

    12. Project code, if applicable. Some specialized cases require a project code. Examples are: training cases, centralized examinations, and other special project examinations.

  4. When the Form 8300 case is assigned to the field:

    1. The SBC is updated to the territory SBC (unique to each territory);

    2. The EGC is updated to the group organization code;

    3. The ERCS status code is updated to status 10; and

    4. ERCS automatically generates a Form 3210 for use in physically transmitting inventory to the field.

  5. BSA coordinators should consult with their managers for additional technical or procedural guidance.

  6. All contacts with FinCEN are made through the BSA Policy Liaison to FinCEN who is on the BSA Policy Office staff.

  7. All external contacts with other Federal agencies must be discussed with the manager prior to attempting contact.

4.26.3.2.8.1  (03-15-2013)
Monthly Reports

  1. Monthly reports for Form 8300 examinations are generated by a WISDM analyst from ERCS and shared with the field territories after the close of the current ERCS cycle..

  2. Monthly reports for Title 31 examinations are generated by a WISDM analyst and shared with the field territories. The Title 31 report cycle mirrors the ERCS reporting cycle.

  3. Coordinators may be requested to prepare, or assist in preparing, specialized or adhoc reports.

  4. BSA field groups may obtain their Form 8300 reports through ERCS. Territory Managers may request additional specific ad hoc reports from the WISDM staff.

  5. Title 31 Inventory Reports are generated for the field groups and territories from the Title 31 database. These reports are based on real-time data and may be produced as desired.

  6. Quarterly reports are generated for Title 31 and Form 8300 examinations as required by the BSA MOU with FinCEN.

  7. Further reporting requirements are listed in the BSA MOU with FINCEN.

4.26.3.2.8.2  (03-15-2013)
Requesting Historical Case Files

  1. To request a closed case file from the ECC-DET, fax the case information to (313) 234-1662, Attention Team Manager 106.

  2. The information (if available) to include when requesting a case is:

    1. Type of case;

    2. Business name and/or dba name;

    3. Employer Identification Number or Social Security Number;

    4. Address;

    5. City, State, and Zip Code;

    6. Closed date (if known); and

    7. Requester name, address and telephone number.

4.26.3.2.8.3  (03-15-2013)
Training

  1. WISDM staff may assist in training BSA field examiners.

  2. WISDM staff may be responsible for training new users on WebCBRS.

  3. The WISDM WebCBRS Analyst is the contact point for technical or procedural questions, and problems related to WebCBRS.

  4. WISDM staff may be asked to teach or assist in creating BSA courses.

4.26.3.2.8.4  (03-15-2013)
Response To Management

  1. WISDM staff will assist in responding to management requests or questions on a timely basis.

4.26.3.2.8.5  (03-15-2013)
Liaison

  1. Each BSA coordinator should establish a liaison with CI.

  2. Contacts with other operating divisions or with state and local government agencies should first be discussed with management.

  3. WISDM managers will ensure that the current MOU for each state agency is followed when exchanging BSA information. WISDM will also ensure that appropriate information is provided to and received from state agencies as provided in the specific MOU.

4.26.3.2.8.6  (03-15-2013)
BSA Web Sites

  1. The BSA web site address is http://mysbse.web.irs.gov/FraudBSA/default.aspx.

  2. The BSA Share Point address ishttp://wsep.ds.irsnet.gov/sites/co/dcse/sbse/fraudbsa/BankSecrecyAct/default.aspx.

  3. The BSA coordinator should access these sites to ensure current program information is observed.

Exhibit 4.26.3-1 
BSA Policy Memo: Form 8300 Exams - Scope and Tax Years

July 17, 2008
Form 8300 - 01-2008
Supplements IRM 4.26.11.4.1.1
 
This is to clarify the procedures regarding the scope and tax years for Form 8300 examinations.
1) The Form 8300 period of examination remains at 12 months. These 12 months are to be the most current complete calendar year, not a random current 12 month period which crosses into another year. All ERCS records will be established as calendar year records.
2) Examiners should select six months for in-depth examination within the calendar year. The six months need not be the most current six months. The months need not be consecutive. The selection of the six months should depend on risk for those months determined by the examiner for the entity being examined. Periods of risk may include, for example times of high volume or identified risk enhancing events.
3) Examining a period beyond the calendar year must be discussed with the group manager and the examiner must complete the Risk Analysis worksheet. Expansion into a second year will require a second set of A2 and P9 records.
4) Because notification is not due until the end of January of the following year, examination for compliance with notification requirements will extend into that year.
5) Notification examination does not require establishing a new year on ERCS. Notification relates back to the year examined.
6) WISDM plans to send out assignments for each calendar year no earlier than February of the following year so that the notification will have been completed by this time.
7) This e-mail does not apply to Form 8300 cases which have already been started by the effective date of this memo.
8) The effective date of this change is July 18, 2008.
 
The changes in procedure will be incorporated in the next revision of IRM 4.26.11.
 
If you have any questions about this guidance, please contact Senior BSA Analyst, Elizabeth Witzgall at (202) 283-2227.

Exhibit 4.26.3-2 
WISDM Case Building Check List

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Exhibit 4.26.3-3 
Title 31 Case Grading Sheet

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Exhibit 4.26.3-4 
Title 31 Case Classification Sheet

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Exhibit 4.26.3-5 
WISDM Title 31 Casebuilding Procedures Memo

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Exhibit 4.26.3-6 
IDRS Instructions for Form 8300

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Exhibit 4.26.3-7 
Form 8300 Case Grading Sheet

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Exhibit 4.26.3-8 
Form 8300 Case Classification Sheet

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Exhibit 4.26.3-9 
ERCS Instructions

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Exhibit 4.26.3-10 
Form 8300 Casebuilding Checklist

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Exhibit 4.26.3-11 
Form 8300 Case File Assembly

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Exhibit 4.26.3-12 
Title 31 Project Codes

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Exhibit 4.26.3-13 
Title 31 Freeze and Reason Codes

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Exhibit 4.26.3-14 
BSA Master ERCS Form 8300 Tracking and Project Codes

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