Because my institution is 'deferred' under 103.70/103.121 and the state doesn't really know what they want us to do yet, how do we go about reporting SARs? All SAR codified regs are for federal banking agencies.
it appears that our state regulator is wanting us to comply with some areas of an AML program, but not enforcing some others. SAR reporting is one of those areas that hasn't really been addressed yet.
Any help would be greatly appreciated. Thanks!

I am hoping it is just me, but how does one get a 'deferral" from Fincen's Chapter X?

We are a state regulated non-bank institution.
§ 103.170 Exempted anti-money laundering programs for certain financial institutions. (2) Subject to the provisions of paragraphs (c) and (d) of this section, a bank (as defined in §103.11(c)) that is not subject to regulation by a Federal functional regulator (as defined in §103.120(a)(2)) is exempt from the requirement in 31 U.S.C. 5318(h)(1) concerning the establishment of anti-money laundering programs...

Believe me, I do not think we are truly exempt from an AML compliance program, as we are required to have a written CIP program, OFAC, training, BSA Officer, etc.

Thanks for the clarification.

Wow. I have never seen that before. I almost don't believe it.