Learn More - Click Here!

New Reply Thread Options
#1459305 - 10/25/10 10:29 PM SAR filing
Anonymous
Unregistered

A SAR was filed on a customer for transactions that occured in June and July. We have received information that this customer is committing fraud and has additional transactions in September and October.

Can we file another SAR now including the September transactions? Since we have received information (from a reputable source) this customer is committing fraud does the 90 day timeline even apply?

Return to Top Reply Quote Quick Reply Quick Quote
#1459313 - 10/25/10 11:57 PM Re: SAR filing Anonymous
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
Yes, you don't have to wait. If you have additional information that would aid law enforcement you should file sooner rather than later.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top Reply Quote Quick Reply Quick Quote
#1459568 - 10/26/10 04:28 PM Re: SAR filing Kathleen O. Blanchard
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,641
Cape Cod
If the customer is committing fraud, I'd get that SAR out as soon as you can assemble the information, and give the customer the boot as soon as possible. You don't want any of the fraudulent actions of your customer coming back to involve the bank in a loss or risk of a besmirched reputation (for banking the SOB).
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top Reply Quote Quick Reply Quick Quote
#1459585 - 10/26/10 05:01 PM Re: SAR filing John Burnett
Midwest Banker Offline
Gold Star
Joined: Nov 2004
Posts: 349
Cheeseland
If you know that a law enforcement or federal agency is investigating them, after you file the updated SAR, you may wish to give them a call as well. .

Return to Top Reply Quote Quick Reply Quick Quote
Quick Reply:
HTML is disabled
UBBCode is enabled




Moderator:  MagicCity, P*Q, Truffle Royale