Third, this data does not directly compare with other information collected on the SAR form with reference to the specific instruments involved in the reported trans- actions, as discussed infra. For example, analysis identified 225 filings that involved annuities, however, Table 1 shows 197 filings that named an annuity owner or ap- plicant as a subject in the narrative, based on a relationship to an annuity. There are fewer annuity owners and applicants than annuity filings, because some narratives placed more emphasis on a gatekeeper or insurance insider as the one whose sus- picious activities were being characterized. The roles.
