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?

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.

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.

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.

I never heard of that recommendation either. We are a small community bank, two branches few tellers and I am the one and only BSA Officer. The tellers complete the CTRs and the Compliance Officer is filing them. I complete the SARs and she files them for us. I, review the CTRs from time to time and make sure there are completed. No auditor or examiner has commented on dual control for this.

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?

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.

Currently our CTRs are completed at branch level and reviewed/filed in compliance by Asst. BSA Officer. ABSAO also files all SARs after a review by BSA/Compliance Officer. We discrete file our SARs but are still paper filing the CTRs. I have been considering discrete filing the CTRs but was not sure if it would be problematic for me (ABSAO) review the report and file the CTRs. We do not have an intra-net so the CTRs would have to be completed here in compliance and submitted, and we are not blessed with a large enough staff to allow one to create the CTR and one to verify/submit.

Our federal examiner monitored for controls surrounding completion of CTRs and actual filing (submission) of CTRs.

I, the BSA Officer completes all SARs. The CTRS are done at branch level and then reviewed by Branch Administration and filed electronically.

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.

There are many ways to handle dual control but I would not consider reporting to the board dual control. The board only knows what you tell them and has no way to know if you missed any dates, properly completed forms, allowed any reported activity to go uninvestigated, etc.

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.

A solution of sorts might be a periodic (monthly, quarterly?) check by someone outside of BSA (which would be everyone else, apparently) to see that dates are being met, forms being completed properly, etc. A second set of eyes so an error doesn't go undetected too long.

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.

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.

Deek - the examiners have no issue with IA being part of the SAR Committee?

Internal audit, really?

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?

And how can you be a committee of one? Isn't that a contradiction in terms?

It's like you're in my mind, jenny!

Just don't ask what happens if there's a tie!

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.

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.