Thread Options
|
#1292153 - 11/24/09 03:11 PM
Re: SAR's timeline
Texas53
|
Power Poster
Joined: Oct 2009
Posts: 3,927
|
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.
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius
|
Return to Top
|
|
|
|
#1292198 - 11/24/09 03:38 PM
Re: SAR's timeline
Doug Hendrickson
|
Gold Star
Joined: Apr 2009
Posts: 450
|
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.
_________________________
CFE, CAMS
|
Return to Top
|
|
|
|
#1292595 - 11/24/09 07:11 PM
Re: SAR's timeline
Kathleen O. Blanchard
|
Power Poster
Joined: Jul 2003
Posts: 2,675
Austin Texas
|
After you've filed the SAR, what's the re-cycle process timeline? 90 days?
_________________________
My comments are absolutely no reflection of, nor influenced by, my employer - take them at your own risk.
|
Return to Top
|
|
|
|
#1297026 - 12/02/09 04:25 PM
Re: SAR's timeline
Pat Patriot Act
|
Gold Star
Joined: Nov 2006
Posts: 336
New England
|
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.
_________________________
just my opinion, based on my 30+ years
GO RED SOX!!!
|
Return to Top
|
|
|
|
#1297726 - 12/03/09 01:18 PM
Re: SAR's timeline
Bobw
|
10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
|
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.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
|
Return to Top
|
|
|
|
#1297769 - 12/03/09 02:28 PM
Re: SAR's timeline
Elwood P. Dowd
|
10K Club
Joined: Jul 2001
Posts: 83,225
Galveston, TX
|
"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.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com
|
Return to Top
|
|
|
|
#1298215 - 12/03/09 06:58 PM
Re: SAR's timeline
rlcarey
|
Power Poster
Joined: Jul 2006
Posts: 4,344
New York City
|
"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.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu
|
Return to Top
|
|
|
|
#1299066 - 12/04/09 06:01 PM
Re: SAR's timeline
ACBbank
|
10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
|
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.)
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
|
Return to Top
|
|
|
|
#1299375 - 12/04/09 09:16 PM
Re: SAR's timeline
Kathleen O. Blanchard
|
Member
Joined: Nov 2008
Posts: 74
New England
|
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.
|
Return to Top
|
|
|
|
|
|