Sorry to post anonymously....but I am doing this as quickly as possible. The question is, "who should be the person listed as the Contact on the SAR form?"

To clarify, what is the best practice? I have not been able to find any direct guidance from FinCEN or from the regulatory agencies regarding contact info. I am wondering if it is best to have a single contact on all of the SARS? This would be for regional size bank.

We place the BSA Officer as the contact on all SARs. We felt it would be good to have one centralized person to complete SARs and be the contact to FiCEN. Plus, who would know more about a suspicious transaction than the BSA Officer of the bank? (We are a small state bank)

Sorry to disagree with the other posters but I would say the person who filed the SAR. This person should have all the knowledge of the incident necessary to write and file the SAR. Otherwise, how can an accuurate, detail SAR be written? Plus, SARs should be maintained in a centralized filed under one person's control.

I file all all SARs for my bank due to my background and experience.

From the SAR Preparation Guidelines:

Items 45, 46, and 47 - Contact Person’s Name - Enter the name of the person who can be contacted for additional information. It would be extremely helpful if the individual identified in this section has specific knowledge of the underlying facts.

This is the only guidance available. I suggest banks use the same contact person on all SARs. Assuming your SAR filing program adheres to the concept that every aspect of your BSA program is supported by "four pillars," you should have a named individual responsible for SAR filing - that's your contact person.