Are examiners and external auditors permitted to take copies of SAR's out of the bank to keep with their workpapers? Thanks.

I know of no prohibition as it is covered under privacy and confidentially clauses in your contracts - however, personally, I chose not to retain copies in my work papers and only refer back to bank records.

There is no reason for regulatory examiners to take copies of SARs from the bank. They have access to the SAR database if the want to use it. As far as other auditors are concerned, I see no reason why they should be allowed to remove SARs from the bank. I know they are covered under privacy and confidentiality clauses, but accidents happen. We do not even share SARs with others within the bank. If they have a need to see them, they come to our facility to look at them, but they are not allowed to remove them from our facility.

When I wear my auditor hat, I always look at the SARs on site. I would not want to take the risk of removing them from the bank. As previously noted, accidents happen. It's just not a good idea.

I see no reason as long as you have a signed confidentiality agreement. That puts the burden on the external auditor or examiner.

I for one always keep copies of any SAR or CTR I am going to reference in my report. We write most of our report off site and it's useful to have a copy to reference back to. Also, if the bank has a question on the report about that item I'll have a copy I can look at. In the instance that an examiner or other auditor ask for copies of work papers, they appreciate having that information as it saves them the time of getting it from the bank.