B: "The [insert regulatory agency] said we are not filing enough SARs."
T: "They said that in the written report!?"
B: "No, they just said it during one of our meetings."
T: "First, your regulatory agency cannot talk. You had a field examiner who said that, not your regulatory agency. Second, it's a silly, irresponsible criticism, one they are explicitly told not to make. See the BSA-AML Examination Handbook, page 20 (document, not pdf):"
The federal banking agencies do not have targeted volumes or “quotas” for SAR and CTR filings for a given bank size or geographic location. Examiners should not criticize a bank solely because the number of SARs or CTRs filed is lower than SARs or CTRs filed by “peer” banks.
If it's dumb for an examiner to say it, I would say it's 34% dumber for an auditor to say it. I would not dispute the criticism, I would ridicule it.
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.