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#1614409 - 10/11/11 05:25 PM State of Mass. Regulated Bank and SAR
Anonymous
Unregistered

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!

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#1614412 - 10/11/11 05:37 PM Re: State of Mass. Regulated Bank and SAR Anonymous
DeeQ Offline
10K Club
DeeQ
Joined: Dec 2002
Posts: 40,762
Turnpike Exit 10
I am hoping it is just me, but how does one get a 'deferral" from Fincen's Chapter X?
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Get your facts first, then you can distort them as you please. - Mark Twain

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#1614419 - 10/11/11 05:54 PM Re: State of Mass. Regulated Bank and SAR DeeQ
Anonymous
Unregistered

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.

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#1614425 - 10/11/11 06:04 PM Re: State of Mass. Regulated Bank and SAR Anonymous
DeeQ Offline
10K Club
DeeQ
Joined: Dec 2002
Posts: 40,762
Turnpike Exit 10
Thanks for the clarification. smile
_________________________
Get your facts first, then you can distort them as you please. - Mark Twain

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#1614441 - 10/11/11 06:39 PM Re: State of Mass. Regulated Bank and SAR DeeQ
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,138
New York City
Wow. I have never seen that before. I almost don't believe it.
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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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