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#1075179 - 11/03/08 03:21 PM Late SAR filing- Counterfeit check
nemsi Offline
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Joined: Nov 2005
Posts: 383
I am filing a SAR for "large" counterfiet check presented to the bank mid 2007- no suspect info available. We have changed our procedures and are enhancing training to ensure this type of late filing doesn't happen in the future. Anything else that I should do at this point?

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#1075302 - 11/03/08 04:43 PM Re: Late SAR filing- Counterfeit check nemsi
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,792
Cape Cod
It would be a good idea to chat with other operational areas of the bank to see if similar roadblocks to timely SAR filings might exist. One common hurdle in banks is timely notice from the legal department when the bank gets involved in litigation. Your case may be an example of that sort of slip. If you've already addressed it, great. But do take a look around at other "silos" of information in the bank.
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#1075391 - 11/03/08 05:39 PM Re: Late SAR filing- Counterfeit check John Burnett
nemsi Offline
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Joined: Nov 2005
Posts: 383
Thanks John! I always appreciate your comments. I will take your advise and talk to other operational areas of the bank.
Right now I'm still in shock! Couldn't believe my eyes.

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#1075414 - 11/03/08 06:11 PM Re: Late SAR filing- Counterfeit check nemsi
NewTooBSA Offline
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Joined: Nov 2005
Posts: 568
Texas
I have a question along those lines. I have found by accident that we have charged off some principal on several loans to a home builder and transferred the loans on the houses into ORE pending litigation. Do we have to file a SAR on this or wait until the houses are sold and then file on any loss we may have?

How about if a company files bankruptcy? At what point should we file? When we are notified or wait and see if a loss occurrs?

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#1075456 - 11/03/08 06:55 PM Re: Late SAR filing- Counterfeit check NewTooBSA
Skittles Offline
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Skittles
Joined: Sep 2002
Posts: 13,963
TN
NewTooBSA - was the activity suspicious? If not, a SAR is not necessary. A bankruptcy or OREO property is not a reason to file a report.
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#1075587 - 11/03/08 08:48 PM Re: Late SAR filing- Counterfeit check Skittles
NewTooBSA Offline
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Joined: Nov 2005
Posts: 568
Texas
Thanks Duchess
That is what I thought but wanted to be sure.

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