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July 15, 2015
All About Escrows
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July 16, 2015
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How to Complete the Closing Disclosure
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#1292900 - 11/24/09 04:15 PM SARs Shared With Third-Party Service Provider
Norrie Offline
Member

Registered: 02/11/08
Posts: 67
If a financial institution has a contract with a third-party service provider who performs transaction monitoring of the bank's account activity, is it okay for the bank to fax copies of filed SARs to the third-party service provider for follow-up monitoring purposes?

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BSA/AML/CIP/OFAC
#1292912 - 11/24/09 04:19 PM Re: SARs Shared With Third-Party Service Provider [Re: Norrie]
John Burnett Offline


10K Club

Registered: 10/27/00
Posts: 32208
Loc: Cape Cod
No. It's not permitted to share the SAR or the fact that the SAR was filed with third parties. Just those who work with them in the bank, audit and examiners, bank counsel and law enforcement.
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John S Burnett
BankersOnline.com

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#1292934 - 11/24/09 04:30 PM Re: SARs Shared With Third-Party Service Provider [Re: Norrie]
Ken_Pegasus Offline

10K Club

Registered: 08/30/01
Posts: 18300
Loc: Another trip around the sun
I'm not certain why a third party would need evidence of prior activity. Regardless, the activity can be described to them without mentioning the SAR filing.
_________________________
Ten percent of life is what happens to you. The other 90 percent is what you do about it. Lou Holtz

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#1293200 - 11/25/09 08:49 AM Re: SARs Shared With Third-Party Service Provider [Re: Ken_Pegasus]
joser Offline
Member

Registered: 09/14/05
Posts: 67
Loc: NJ
Just a reminder -- Faxes are not a secure media

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