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#1291771 - 11/23/09 07:47 PM Attorney to review SAR?
CH Offline
Member
Joined: Feb 2005
Posts: 51
Georgia
Our CEO wants our attorney to review a SAR before we file it.
Our BSA officer is reluctant to tell him no. How can she
say 'no' and get her message across?

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#1291784 - 11/23/09 08:01 PM Re: Attorney to review SAR? CH
Data Offline
100 Club
Data
Joined: Oct 2002
Posts: 226
Houston
Very good question. Five years ago our CEO read a SAR and told the BSA Officer to delete the narrative and just write "see attached" The BSA Officer just did it instead of dealing with it. When we were cited a violation at the next exam guess who took the heat? If you guess the CEO you are wrong.
_________________________
One thing change will bring is something new.

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#1294367 - 11/27/09 03:09 PM Re: Attorney to review SAR? Data
Bobw Offline
Gold Star
Bobw
Joined: Nov 2006
Posts: 336
New England
I totally agree. The CEO is wrong with this request and you and your FI are at risk involving someone that do not need to know the details
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just my opinion, based on my 30+ years

GO RED SOX!!!

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#1295777 - 11/30/09 09:17 PM Re: Attorney to review SAR? Bobw
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,348
New York City
By "our attorney," I assume you mean Bank Counsel? If so, its not completely out of the ordinary. This is of course, assuming that the attorney has a very good understanding of the BSA rules and requirements. Some do, some do not.

If not, I would agree with the other posters in that it serves no purpose at all.
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#1295817 - 11/30/09 09:39 PM Re: Attorney to review SAR? CH
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
If your bank's attorney knows more about SAR filing than your BSA officer, your bank is in sad shape. All you're going to get is an over anxious editor @ $200 an hour...

Telling the CEO "No?" Naaah, just tell him or her it's a profound waste of money and it is simply not necessary. I have no patience with BSA officers who will not step up to the plate, but I don't expect people to hang their career on straightening out the CEO. Leave a paper trail and go on to what's next.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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