#1447515 - 09/23/10 05:33 PM
Re: SAR/ Mgmt.
Gigi03
|
Diamond Poster
Joined: Nov 2009
Posts: 1,331
Hoosier Country
|
Who is responsible for filing the SAR?
My long-time mentor, who spent 30+ years working in corporate governance and compliance, told me that, as a BSA Officer, I need to file SARs when they should be filed. She told me "If you find something and you know you have to file a SAR, you file a SAR. If *I* tell you not to file it, you still file it. If the CEO tells you not to file it, you still file it." It's a rule I've lived by for over 6 years now...
Then again, I do understand that certain FIs operate differently and that senior management has final say. I do not agree with that, but it's reality. In that case, if your job is in danger, you document the heck out of the whole thing to show that you wanted to file but were prevented by the powers that be. Cover yourself.
_________________________
CRCM + CAMS = certified compliance nerd
Opinions expressed in these threads are my own and not my employer's.
|
Return to Top
|
Reply
Quote
Quick Reply
Quick Quote
|
|
|
|
|