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#1273932 - 10/26/09 07:25 PM SAR committe meeting frequency
chatty Offline
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Joined: Feb 2006
Posts: 34
How frequently does your SAR committee meet to determine whether SAR's should be filed? Weekly, bi-monthly(assuming you have activity that may warrant filing)? Someone told me recently their committee meets monthly and I wondered if that is too infrequent. I know your policy should state the frequency.

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#1274001 - 10/26/09 07:57 PM Re: SAR committe meeting frequency chatty
EdieT Offline
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Joined: May 2009
Posts: 76
PA
We call a meeting monthly (in general). I save up all SAR's & present at one timem aking sure they all meet the 30 day timeline.
Having said that, if we feel that there is a burning reason to call a meeting, we will do so as soon as possible.
I don't believe I have read anything that requires meetings at certain intervals.

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#1275284 - 10/27/09 07:04 PM Re: SAR committe meeting frequency chatty
Elwood P. Dowd Offline
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Personal opinion, strongly held: if a bank makes SAR filing decisions once a month it's a clear indication of indifference. The question I usually ask is "How often does your loan committee meet?" I would use that answer in comparison to the SAR committee meeting frequency as a gauge of their relative importance.

There are lots of variables here, case volume and committee structure among them, but I suggest you start with a discussion of "weekly, as necessary;" i.e. if there is nothing to talk about this week, we do not meet, but we meet in any week where there is something to talk about.
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#1275324 - 10/27/09 07:24 PM Re: SAR committe meeting frequency Elwood P. Dowd
CantBeShocked Offline
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Posts: 260
MS
I make the decision as to whether or not to file SARs except in certain situations and we meet as needed in that case. Otherwise, we meet to discuss suspicious customers on a quarterly basis. We then decide when to close accounts based upon activity or when to discuss activity with a customer (such as giving them a CTR brochure if warranted), etc.
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#1275459 - 10/27/09 09:05 PM Re: SAR committe meeting frequency CantBeShocked
chatty Offline
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Joined: Feb 2006
Posts: 34
Thank you. I like weekly meetings.

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#1275471 - 10/27/09 09:14 PM Re: SAR committe meeting frequency chatty
J2C Offline
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Big Brother knows and that's a...
We meet on an as needed basis.
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#1276438 - 10/28/09 07:41 PM Re: SAR committe meeting frequency J2C
EdieT Offline
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EdieT
Joined: May 2009
Posts: 76
PA
Ken,
When I said monthly (in general), I should have been more specific. We went from previously (with others in the BSA jobs) filing 2 SAR's per year to me filing 25 since April 2009.
It just has seemed the need to file has happened that I'll get 3 or 4 at one time (within a week or so). The SAR Committee appreciates reviewing more than one at a time rather than one at a time since we are a rather small bank & everyone wears many hats. I TOTALLY understand the importance of timely filing, and have consistently filed as soon as possible, but out here in the real world, sometimes it's not practical to meet weekly. Don't take it as nonchalance, just practicality.

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#1295640 - 11/30/09 07:59 PM Re: SAR committe meeting frequency EdieT
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Can anyone tell me who is all on your SAR committee. We are looking at ours and trying to decide how many is to many and who should be included. thanks
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#1295662 - 11/30/09 08:09 PM Re: SAR committe meeting frequency Hockey Rules
Nancyod Offline
Member
Joined: Nov 2008
Posts: 74
New England
BSA/Compliance Officer, Security Officer, and President/CEO.

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#1295685 - 11/30/09 08:19 PM Re: SAR committe meeting frequency Nancyod
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Great thanks, how do your employees notify you that there is suspicious activity? Is there a form they fill out with the information in question?
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#1295750 - 11/30/09 08:57 PM Re: SAR committe meeting frequency Hockey Rules
NewTooBSA Offline
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Joined: Nov 2005
Posts: 568
Texas
We have several methods with the most frequent one being email. Anyone who has supicious activity sends an email to the BSA Department with details of what they think is suspicious and we take it from there. Emails have their own date and time stamp so it is easy to determine when the case was received.
2nd method is phone call but again, I usually request an email with details so I can use that as the beginning date for the investigation.
We tried the form but found most people found it intimidating or time consuming so they never reported anything. Since we have changed it to an email request, everyone knows the minimum information required is: name of person conducting suspicious activity, account number if any, and what the suspicious activity is. If we research and determine we need details, we know who to contact.

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#1295758 - 11/30/09 09:05 PM Re: SAR committe meeting frequency Hockey Rules
nemsi Offline
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Joined: Nov 2005
Posts: 383
We have 3 SAR committee members- VP of Operations, Security Officer and BSA Officer. We're a small bank and meet as needed.

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#1295879 - 11/30/09 10:20 PM Re: SAR committe meeting frequency nemsi
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Thanks so much for all your help.
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