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#1471709 - 11/23/10 05:42 PM SAR report to BOD
Madawaska Offline
100 Club
Joined: Sep 2008
Posts: 108
Sorry to bring up an old topic, but I would like some up-to-date clarification:

For SAR reports to the Board of Directors, what exactly is the type of information you are reporting to them? What is best practice?

Do you disclose the name(s) of the customers?
A brief description of the type of filing?
Amount involved? Loss and/or recovery?

Your help is very much appreciated.

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#1471712 - 11/23/10 05:44 PM Re: SAR report to BOD Madawaska
Doug Hendrickson Offline
Power Poster
Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
We do not disclose the name of the customer. I give the board a running y-t-d list of SAR filings, with date of filing, description of the type of filing [e.g., structuring] and amount involved. We haven't (thankfully) had a loss, but would report that as well.
I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1471718 - 11/23/10 05:48 PM Re: SAR report to BOD Madawaska
Aggs Offline
Diamond Poster
Joined: Nov 2009
Posts: 1,331
Hoosier Country
Back when this was my job (up until a year ago), I submitted a SAR report that had these fields:

Date activity discovered
Date report filed
Filing type (i.e. structuring, mortgage fraud, etc.)
Brief description
Actual loss

I did NOT identify customers/suspects by name. I was told a long time ago not to do that, because you don't want to give away too much information. Especially if you're a community bank and directors know the customers personally, etc.

I would only divulge more info if I got a request from my boss (the CEO) or the chairman of the audit committee, who I also reported to. That was extremely rare that they wanted more information and only happened when we were looking at a pretty substantial loss. Very rare.
CRCM + CAMS = certified compliance nerd

Opinions expressed in these threads are my own and not my employer's.

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#1471831 - 11/23/10 07:17 PM Re: SAR report to BOD Aggs
DebL Offline
Gold Star
Joined: Jan 2007
Posts: 314
Ditto Aggs ^^^

Plus we include our internal reference number on the report. It doesn't really do the BOD any good, but an auditor or examiner can tie that number back to the actual SAR to verify that we are reporting things accurately.
Of all the things I've lost, I miss my mind the most.

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#1471892 - 11/23/10 07:55 PM Re: SAR report to BOD DebL
J2C Offline
Diamond Poster
Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
I give them everything I write in the narrative and I remove names.
My opinion is mine only- not my employer's!

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#1471914 - 11/23/10 08:10 PM Re: SAR report to BOD J2C
80's Lady Offline
Gold Star
Joined: Apr 2007
Posts: 295
I also use a numbering system and just write a brief synopsis, but never any names because Board Minutes (including your report)can be subpoenaed and even if they are not looking for SAR info, there it could be for someone to read that shouldn't.
I use to think I was a smart cookie before I started working in Compliance. Now, I have mastered the art of the blank stare!

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#1472039 - 11/23/10 09:33 PM Re: SAR report to BOD 80's Lady
Dallas Fan Offline
100 Club
Joined: Feb 2008
Posts: 219
I use numbers instead of names on the written materials but I do inform the BOD of the names verbally. I disgree with the notion that the names of SAR suspects be kept from the board.

I don't see how your Board members can be informed if they don't know the names of the suspects. Just keep the names out of the board minutes. The discussion of names should be off the record for reasons of confidentiality. I think it's important that the Board know who they are dealing with in case there is a loan request or other transcation requested by a SAR suspect.

I also collect any information that I hand out to the Board regarding SAR suspects prior to my departure form the board room. This may help alleviate any inadvertant release of information by a board member if they take the information packet home or leave it in their car.
Last edited by Dallas Fan; 11/23/10 09:35 PM.
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#1472053 - 11/23/10 09:48 PM Re: SAR report to BOD Dallas Fan
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
In a comment letter on EGRPRA the American Bankers Association suggested that the requirement to report SARs to the board be discontinued entirely. A couple of key phrases from the letter are to the effect that the requirement, " inconsistent with rational risk management responsibilities... and " adds further risk to information security issues without concomitant benefit to the bank."

I agree with the ABA; reporting every SAR to the board is a dumb idea to begin with. It's required by the federal functional regulatory agencies, not FinCEN.

I cannot make any argument that the board needs specific SAR information unless the filing relates to a fact situation that rises to the level of the board's fiduciary responsibility; e.g. embezzlement, a major loan loss due to fraud, etc. There, the board should be told not because a SAR was filed, but because they should simply be told.
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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