I have a slightly different mindset on the principal, and am going to use a quote that Randy had in another forum to explain. (Thanks Randy)
"Point them to pages 75-76 of the examination manual. Unless these really are a case of blatent poor decision making, I would be kicking this up to the field office, DC and then to the ombudsman:
"The decision to file a SAR is an inherently subjective judgment. Examiners should focus on whether the bank has an effective SAR decision-making process, not individual SAR decisions. Examiners may review individual SAR decisions as a means to test the effectiveness of the SAR monitoring, reporting, and decision-making process. In those instances where the bank has an established SAR decision-making process, has followed existing policies, procedures, and processes, and has determined not to file a SAR, the bank should not be criticized for the failure to file a SAR unless the failure is significant or accompanied by evidence of bad faith."
When the OCC reviewed our SAR's and transactions that we did not file, they looked at the process and the underlying documentation. While the physical filings belonged to me, there were others involved. Why? To ensure a balance rather than just one person's decision. There are many automatic SAR's - structuring being the most common, but when there was something out of the ordinary, the CEO, executives from operations and lending got together, just to make sure that all were on the same page.
If the decision to file a SAR is rejected, the President will be the one explaining to the examiners.
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Integrity. With it, nothing else matters. Without it, nothing else matters.