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#1465269 - 11/08/10 03:33 PM
BSA - dual control?
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100 Club
Joined: Dec 2005
Posts: 153
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My bank hired a new BSA officer. We were previously written up because we had the same person completing the paperwork and filing the SAR's and CTR's. We were told we needed to have dual control. The new BSA officer now wants to do both complete them and sign them and send them in. What do you do at you bank?
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#1465276 - 11/08/10 03:37 PM
Re: BSA - dual control?
small town girl
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Power Poster
Joined: Oct 2009
Posts: 3,927
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Our tellers generally fill out a large transaction form which gets sent to the filer of the CTRs. She reviews the LCTF, completes the CTR and submits it. I do periodic reviews of the CTRs and the over $10,000 report to ensure completeness.
I'm the only one who completes and files SARs (BSA Officer). I can often see the value of dual control, but not in filing SARs or CTRs, especially given the size of staff.
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius
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#1465347 - 11/08/10 04:52 PM
Re: BSA - dual control?
Doug Hendrickson
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Gold Star
Joined: Nov 2005
Posts: 383
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We are a small multi bank holding compay-3 small banks- and I complete ALL the SARs and a fairly large number of the CTRs. I am the BSA Officer. I have never had an OCC examiner question us on our policy.
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#1465419 - 11/08/10 06:17 PM
Re: BSA - dual control?
nemsi
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Member
Joined: Oct 2010
Posts: 97
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If the new BSA Officer wants to do both, you'll probably get written up again. We are a small community bank, but it has never been recommeded to us to have dual controls. Our BSA Compliance Department is 2-people strong. One handles the CTRs while the other SARs. Although both individuals can handle both functions.
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#1465523 - 11/08/10 08:02 PM
Re: BSA - dual control?
Lilly C
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10K Club
Joined: Jul 2001
Posts: 84,530
Galveston, TX
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Original poster:
"We were previously written up because we had the same person completing the paperwork and filing the SAR's and CTR's."
Written up by whom? Internal audit or examiners?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#1465624 - 11/08/10 09:42 PM
Re: BSA - dual control?
rlcarey
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Diamond Poster
Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
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OCC Bank. BSA/Compliance Officer files all SARs, no one else does. CTR's are completed by the branches and reviewed/signed off on by BSA Officer.
Just started using discrete efiling and BSA Officer is completing and signing (PIN) the CTR. No dual control issues.
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My opinion is mine only- not my employer's!
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#1469452 - 11/17/10 09:29 PM
Re: BSA - dual control?
CompliKat
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Power Poster
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
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Our federal examiner monitored for controls surrounding completion of CTRs and actual filing (submission) of CTRs.
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Life without Jesus is like an unsharpened pencil - it has no point.
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#1469872 - 11/18/10 04:36 PM
Re: BSA - dual control?
BrendaC
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Platinum Poster
Joined: Feb 2007
Posts: 827
In the Sun
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I, the BSA Officer completes all SARs. The CTRS are done at branch level and then reviewed by Branch Administration and filed electronically.
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Faith is seeing light with your heart when all your eyes see is darkness...
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#1473502 - 11/29/10 11:12 PM
Re: BSA - dual control?
Lele
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Diamond Poster
Joined: Mar 2007
Posts: 2,108
gone fishin'
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I had the same thing brought up by an Internal Auditor. If you report your SARs to the Board (which you should) - then that's your dual control.
The branch is responsible for the CTRs, then they send them to a centralized teller who reviews and sends them in for me. So that's dual control.
_________________________
My opinions are my own, and not that of my employer.
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#1473511 - 11/29/10 11:46 PM
Re: BSA - dual control?
Kathleen O. Blanchard
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Diamond Poster
Joined: Mar 2007
Posts: 2,108
gone fishin'
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Very true MS Kaybee and I totally agree.
The problem is I don't have (& I think most of us on this post don't have) anyone else. Even with recommendations from my Auditors and my EIC - I still haven't gotten help.
I report to the Board SARs filed and not filed. It's the best I can do.
_________________________
My opinions are my own, and not that of my employer.
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#1473544 - 11/30/10 11:26 AM
Re: BSA - dual control?
Kathleen O. Blanchard
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10K Club
Joined: Jul 2001
Posts: 84,530
Galveston, TX
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I'm not sure why any auditor or examiner would be getting bent out of shape over this one audit step. All it really says is: "Provide for dual controls and the segregation of duties to the extent possible." If they see additional opportunitites for improvement they should specifically tell them to you or shut up.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#1473552 - 11/30/10 01:30 PM
Re: BSA - dual control?
rlcarey
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10K Club
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
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We formed a SAR committee (Internal audit, compliance and BSA) to review all cases before filing or not filing. Minutes are recorded and reported to the BOD.
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Get your facts first, then you can distort them as you please. - Mark Twain
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#1473568 - 11/30/10 01:51 PM
Re: BSA - dual control?
Retired DQ
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10K Club
Joined: Jul 2004
Posts: 19,008
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Deek - the examiners have no issue with IA being part of the SAR Committee?
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With the lights out, it's less dangerous.
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#1473714 - 11/30/10 04:34 PM
Re: BSA - dual control?
Retired DQ
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Diamond Poster
Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
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We formed a SAR committee (Internal audit, compliance and BSA) to review all cases before filing or not filing. Minutes are recorded and reported to the BOD. Internal audit, really?
_________________________
My opinion is mine only- not my employer's!
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#1473717 - 11/30/10 04:36 PM
Re: BSA - dual control?
J2C
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Power Poster
Joined: Oct 2009
Posts: 3,927
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I'm the only member of the SAR committee, but I do bounce most items against the internal auditor. Why? Because she's one of the few who cares and who understands and has a viewpoint.
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius
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#1473727 - 11/30/10 04:41 PM
Re: BSA - dual control?
Doug Hendrickson
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Diamond Poster
Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
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I'm the only member of the SAR committee, but I do bounce most items against the internal auditor. Why? Because she's one of the few who cares and who understands and has a viewpoint. I agree. I usually discuss things with the audior as well for the very reasons you stated, but to make them a formal member of a committee of the bank, I would say would compromise their independence and how can they aduti the SAR process when they are involved in it?
_________________________
My opinion is mine only- not my employer's!
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#1473774 - 11/30/10 05:18 PM
Re: BSA - dual control?
J2C
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10K Club
Joined: Jul 2004
Posts: 19,008
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I'm the only member of the SAR committee, but I do bounce most items against the internal auditor. Why? Because she's one of the few who cares and who understands and has a viewpoint. I agree. I usually discuss things with the audior as well for the very reasons you stated, but to make them a formal member of a committee of the bank, I would say would compromise their independence and how can they aduti the SAR process when they are involved in it? It's like you're in my mind, jenny!
_________________________
With the lights out, it's less dangerous.
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#1473776 - 11/30/10 05:19 PM
Re: BSA - dual control?
Kathleen O. Blanchard
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10K Club
Joined: Jul 2004
Posts: 19,008
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I'm the only member of the SAR committee, but I do bounce most items against the internal auditor. Why? Because she's one of the few who cares and who understands and has a viewpoint. And how can you be a committee of one? Isn't that a contradiction in terms? Just don't ask what happens if there's a tie!
_________________________
With the lights out, it's less dangerous.
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#1473794 - 11/30/10 05:38 PM
Re: BSA - dual control?
A_G
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100 Club
Joined: Feb 2008
Posts: 219
RIC
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I just changed jobs but at my former FRB bank, Internal audit had a similar finding and wanted dual control. At that bank I (Compliance officer)trained a CSR/Teller on completing CTRs and she would review all CTRs that I drafted prior to submitting them. Her attention to detail was one of her best qualities. I would simply have her initial in the bottom right corner once she was done. The examiners were okay with this process.
Similarly, I would have either our general counsel or chief of ops review any SARs prior to submission. This too passed the examiners scrutiny.
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#1473825 - 11/30/10 06:17 PM
Re: BSA - dual control?
A_G
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Power Poster
Joined: Oct 2009
Posts: 3,927
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The problem with most committees around here is trying to get others to a) give a damn and/or b) find the time. I would've created a committee of me and the auditor, but I didn't want to formalize it so that she can still maintain an appearance (and, in her case, a reality) of independence.
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius
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