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#1510489 - 02/15/11 09:58 PM
Re: SAR Committee
complybsa
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Power Poster
Joined: Oct 2009
Posts: 3,927
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If the President is on the Board as well, I vote no. In fact, I'd probably vote no even if he/she were not on the Board. I tend to be overly-cautious about the information relative to SARs and might consider the President too close to the Board and wouldn't want to put him/her in a possibly awkward situation.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius
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#1510521 - 02/15/11 10:44 PM
Re: SAR Committee
Doug Hendrickson
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Power Poster
Joined: Jul 2006
Posts: 4,349
New York City
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What you have seems more than enough to me. As long as you keep Management and board abreast of your activities, I see no reason to include the President on the committee.
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu
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#1510546 - 02/16/11 12:24 AM
Re: SAR Committee
ACBbank
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100 Club
Joined: Aug 2010
Posts: 113
Long Beach, CA
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I vote to keep the CEO out. They like to be up in the kool-aid and they don't even know what flava' is.
Based on your org chart, i would also include the investigator(s), analyst(s) or anyone else involved in your SAR process for additional input.
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#1510595 - 02/16/11 01:06 PM
Re: SAR Committee
complybsa
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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I've seen examiners criticize having the CEO on the committee because his or her presence would have a chilling effect on decision making; e.g. who's going to vote against him? Actually, that may or may not be true based on the CEO's and the committee members' personalities.
Part of the answer may lie in why the board would make such a suggestion. What's up?
If your CEO could direct every decision by the committee, then your bank would be better off letting the CEO make the decisions by himself after receiving a recommendation from the committee. That should satisfy the board and put the responsibility squarely where it belongs...
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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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#1510606 - 02/16/11 01:45 PM
Re: SAR Committee
Elwood P. Dowd
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Member
Joined: Jul 2009
Posts: 52
Delaware
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Our committee consists of the following:
BSA Officer Compliance Officer Director of Operations Director of Retail Services & Support Security Officer
Senior Management receives a monthly report & I would agree that having the CEO involved is a no no!
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#1510608 - 02/16/11 01:47 PM
Re: SAR Committee
Elwood P. Dowd
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Platinum Poster
Joined: Jan 2006
Posts: 642
Missouri
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My group includes 3 external directors (Board has 9 total, 5 are external) plus the Risk Managers (5 of us) who are charged with researching and creating SARs. The full board only gets totals and reasons, no names. OCC likes it and it keeps Senior Management out.
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Born once? Die twice. Born twice? DIE ONCE!
Loan Review, HMDA, ALLL
Opinions are my own and do not reflect any others
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#1511006 - 02/16/11 08:31 PM
Re: SAR Committee
Ted Dreyer
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Diamond Poster
Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
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My SAR committee consists of: Me (BSA Officer) VP Deposit Operations Security Officer VP Credit Officer and EVP/CFO (which I do not agree with AT all, and it has been an issue with some of our SAR filings that everyone agreed on but he did not). I also feel as though he may discuss some of what is discussed in our meeting with other Execs based on some other conversations that have happened after our meetings.
I wish that the examiners would say something about it...but until they do he will remain.
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My opinion is mine only- not my employer's!
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#1511011 - 02/16/11 08:35 PM
Re: SAR Committee
J2C
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10K Club
Joined: Sep 2002
Posts: 13,965
TN
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While I understand a 'SAR Committee', I also don't agree that one person can prevent a SAR filing. If the BSA Officer believes the activity is suspicious and they are on the line, they should have final say.
Just my humble opinion, though.
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My Opinions Only
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#1511019 - 02/16/11 08:42 PM
Re: SAR Committee
Skittles
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Power Poster
Joined: Oct 2009
Posts: 3,927
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I agree. I don't have a formal committee, but I do discuss SARs with the appropriate personnel (head of ops, head of lending, internal auditor, etc.) to get other viewpoints. I think of them as helping me (BSA Officer) to make the decision, not making it for me.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius
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#1511057 - 02/16/11 09:09 PM
Re: SAR Committee
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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Oh, I completely agree with that as well, but that hasn't stopped the disagreements from occurring.
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My opinion is mine only- not my employer's!
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#1512578 - 02/21/11 11:48 AM
Re: SAR Committee
complybsa
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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...anywhere in writing does it say that the contents of a SAR CAN NOT be disclosed to the Bd of Directors. Ted provided the summary quote. You can tell the board as much or as little as you wish about SAR specifics. Philosophies have generally evolved to the point where most banks opt for telling the board very little. I think that is appropriate for a long list of reasons. However, lots of people read over the last sentence of that directive: ...management should provide sufficient information on its SAR filings to the board of directors or an appropriate committee in order to fulfill its fiduciary duties." There are instances where the board needs the explicit details. They do not need them because a SAR was filed. They need them because something happened that they should have been told about. On occasion, I've seen banks use "SAR confidentiality" as a reason to keep the board in the dark. That's a greater sin than over disclosing.
_________________________
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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#1512800 - 02/22/11 02:55 PM
Re: SAR Committee
Elwood P. Dowd
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10K Club
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
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SAR Committee:
BSA Officer Compliance Officer Director if Internal Audit
Our monthly reports include case numbers and detailed scenarios. No other info about the suspect is disclosed.
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Get your facts first, then you can distort them as you please. - Mark Twain
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#1512816 - 02/22/11 03:25 PM
Re: SAR Committee
Retired DQ
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Power Poster
Joined: Jun 2003
Posts: 7,659
Florida
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Ted and Ken gave great information about the SAR and Board (and Ken mentioned " Philosophies have generally evolved to the point where most banks opt for telling the board very little. I think that is appropriate for a long list of reasons."
One thing to be sure that while the SARs are documented in the minutes, any details discussed should not be included. Minutes may be reviewed by various reviewers, insurance, CPA's etc., and are subject to discovery in a lawsuit. That would break the confidentiality portion.
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#2100759 - 09/28/16 03:04 PM
Re: SAR Committee
complybsa
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New Poster
Joined: Apr 2016
Posts: 1
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Does anyone have a SAR committee charter they would be willing to share? We currently have a SAR committee but would like to create a formal charter that each member would have to sign which spells out their duties / requirements as a member of the committee and speaks to the confidentiality of the committee.
Any assistance would be appreciated.
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#2100781 - 09/28/16 04:09 PM
Re: SAR Committee
complybsa
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Member
Joined: Jul 2013
Posts: 80
Wisconsin
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SAR Committee:
Compliance Officer (Me) BSA Officer (Me) Security Officer (Me) Internal Auditor (Me)
I guess the decision is up to umm me lol
As for reporting the SARs to the board it is very vague. Basically a SAR was filed for check kiting. My predecessor did a very good job at training our board on what can be disclosed to them in regards to SARs.
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#2100789 - 09/28/16 04:36 PM
Re: SAR Committee
complybsa
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100 Club
Joined: Nov 2010
Posts: 180
Central IL
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We have a BSA committee consisting of the BSA officer (me); the assistant BSA officer (compliance officer); a third employee (loan officer been at the bank over 20 yrs) that make all the decisions for SARs. Our CEO is a board member as is our President. I would vote a big NO.
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For when I am weak, then I am strong. 2Cor 12:10
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#2101688 - 10/04/16 08:02 PM
Re: SAR Committee
complybsa
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Member
Joined: Mar 2010
Posts: 72
New York
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SAR Committee
Myself (BSA & Security Officer) Compliance Manager Risk Manager Controller Loan Portfolio Manager Operations Manager
Executive management is not invited to our party.
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Move along there's nothing to see here.
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#2101736 - 10/04/16 09:54 PM
Re: SAR Committee
complybsa
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Platinum Poster
Joined: Feb 2002
Posts: 582
USA
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SAR Committee is Executive Committee of the bank - top dogs from each area including marketing and personnel.
Last edited by Just Jean; 10/04/16 09:56 PM. Reason: corrected
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#2101752 - 10/05/16 10:40 AM
Re: SAR Committee
Just Jean
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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Marketing? Personnel?
Personal opinion only, but no seat at the table for either as far as I'm concerned. It's unlikely that one would bring any relevant experience or expertise. The other might learn things that could affect other unrelated decisions regarding an employee's future.
_________________________
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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