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#1292140 - 11/24/09 03:05 PM SAR's timeline
Texas53 Offline
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What is the timeline that a SAR's has to be filed. I have heard so many different answers. Is it 30 days from when suspicious activity is discovered or 30 days from when a decision has been made to do a SAR's?

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#1292153 - 11/24/09 03:11 PM Re: SAR's timeline Texas53
Doug Hendrickson Offline
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No later than 30 calendar days from the date of the initial detection of the suspicious activity, unless no suspect can be identified, in which case the time period is extended to 60 days.

The time to file a SAR starts when the organization, in the course of its review, reaches the position in which it knows, or has reason to suspect, that the activity or transactions under review meets one or more of the definitions of suspicious activity.
Last edited by Doug Hendrickson; 11/24/09 03:13 PM.
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#1292198 - 11/24/09 03:38 PM Re: SAR's timeline Doug Hendrickson
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Exactly as Doug says. What my organization does, to clear up any ambiguity, is take the position that the clock starts when our SAR Committee decides to file. With that being said, if something is pretty clear cut - like a takeback or transaction cancellation to avoid a CTR - we try to get the SAR out less than 30 days after the transaction occured just to be safe.
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#1292212 - 11/24/09 03:46 PM Re: SAR's timeline Pat Patriot Act
Kathleen O. Blanchard Offline

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The one caveat I would add is that you are expected to conduct your investigation expeditiously....don't take your sweet time investigating and making a decision.

If you have everything written up for your file, there should be no reason it takes 30 days to get the SAR out the door once the decision is made. Create a process where the writeup for the decision is what you would put in the SAR. Don't recreate the wheel.
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#1292595 - 11/24/09 07:11 PM Re: SAR's timeline Kathleen O. Blanchard
RBanker Offline
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After you've filed the SAR, what's the re-cycle process timeline? 90 days?
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#1297016 - 12/02/09 04:21 PM Re: SAR's timeline RBanker
Kathleen O. Blanchard Offline

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That is Fincen's recommendation and has become the regulatory expectation.
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#1297026 - 12/02/09 04:25 PM Re: SAR's timeline Pat Patriot Act
Bobw Offline
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I note there is a SAR Committee? I don't know how large of a FI you are, but SARs by Committee is risk I would not want to have. SARs are be very confidential and I would have a problem with too many people knowing that does not need to know.
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#1297726 - 12/03/09 01:18 PM Re: SAR's timeline Bobw
Elwood P. Dowd Offline
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Using a committee to make SAR filing decisions is accepted as a "best practice."

To stay on the issue that began this thread and avoid a hijacking, I will just point out that if there is only one SAR decision maker the time when the clock begins to run on filing becomes very vague. If its a committee decision, it's obvious.
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#1297769 - 12/03/09 02:28 PM Re: SAR's timeline Elwood P. Dowd
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"If its a committee decision, it's obvious."

Of course this is true as long as the committee meets on a timely basis. I have seen banks that decision by committee and then the regular committee meetings get cancelled and then you have a suspicious activity in which there is no doubt that is SAR-able and it sits around for several months prior to filing. I have seen the regulators take a dim view of that meeting the 30-day filing requirement.
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#1297821 - 12/03/09 03:02 PM Re: SAR's timeline rlcarey
Kathleen O. Blanchard Offline

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Regardless of the process used the bank must take this seriously. Investigations must be conducted "expeditiously" as I mentioned above, meetings must be held regularly, and SARs filed quickly once decisions are made.

To do otherwise is to post a target on your back.
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#1298215 - 12/03/09 06:58 PM Re: SAR's timeline rlcarey
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Originally Posted By: rlcarey
"If its a committee decision, it's obvious."

Of course this is true as long as the committee meets on a timely basis. I have seen banks that decision by committee and then the regular committee meetings get cancelled and then you have a suspicious activity in which there is no doubt that is SAR-able and it sits around for several months prior to filing. I have seen the regulators take a dim view of that meeting the 30-day filing requirement.


Randy brings up a very valid point here. My current FI is trying to take the committee approach, but every month we end up coming really close to the 30 days. I'm not a big fan of SAR committee's and I'm hoping to convince to President to cancel this one.
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#1299066 - 12/04/09 06:01 PM Re: SAR's timeline ACBbank
Elwood P. Dowd Offline
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Consistent with the question that started the thread, my observation was about the relative ease in marking the time a committee made a decision vs. when an individual made or should have made a decision. The point is not affected by the frequency of committee meetings.

It is an article of faith that 1) investigations should be conducted promptly and 2) SAR committees should meet regularly. My standard for comparison is how often does the loan commitee meet? There are variables...but to be taken seriously, the SAR committee should meet at least weekly as necessary. (If there are no cases to discuss they do not meet. If "Mr. Big" committee member is out, they meet anyway and tie votes result in a SAR filing.)
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#1299227 - 12/04/09 07:32 PM Re: SAR's timeline Elwood P. Dowd
Kathleen O. Blanchard Offline

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I find that when SAR committee meetings are regularly pushed off for various reasons, the bank is not taking BSA seriously. They probably don't push off loan committee, ALCO, audit committee, etc.
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#1299375 - 12/04/09 09:16 PM Re: SAR's timeline Kathleen O. Blanchard
Nancyod Offline
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We don't meet on a scheduled basis. Whenever I complete an investigation, I call a meeting immediately and we decide whether to file or not.

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