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#1730121 - 08/13/12 03:28 PM
SAR Summary to Report to Board of Directors
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100 Club
Joined: Jul 2009
Posts: 218
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We have always provided a copy of each SAR to our board of directors. We are switching to a summary. I was wondering if anyone would be willing to share what they usually provide and what they leave out.
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#1730132 - 08/13/12 03:42 PM
Re: SAR Summary to Report to Board of Directors
Juby
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Platinum Poster
Joined: Jan 2011
Posts: 763
Top of the world... and never ...
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At my former institution we went to a number system. Instead of reporting the whole SAR to the board, we reported SAR #75 (as an example).
As for the information reported in the board minutes we kept it really brief... the activity type (structuring, AML or general sketchy behavior). Total amount of the filings suspicious funds and a summary outline of what the activity was... For example, customer made 2 deposits for $9900 after asking how to avoid reporting.
The board by virtue of their role could access the full SAR if they wanted but we stopped giving them any real identifying information for board folders and board minutes.
Cheers!
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#1730138 - 08/13/12 03:46 PM
Re: SAR Summary to Report to Board of Directors
Juby
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10K Club
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
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I only report the number of SARs files, and the general purpose:
4 filed: 2 Structuring, 1 Money Exchange, 1 Mortgage fraud.
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#1730157 - 08/13/12 04:04 PM
Re: SAR Summary to Report to Board of Directors
#Just Jay
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Power Poster
Joined: Jul 2002
Posts: 6,726
the sandy shore
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I only report the number of SARs files, and the general purpose:
4 filed: 2 Structuring, 1 Money Exchange, 1 Mortgage fraud. I like this method too. If the BOD needs more information, they can come ask for it, and it's easy to tie out for audit purposes. In some cases, this being one of them, less is more.
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#1730172 - 08/13/12 04:21 PM
Re: SAR Summary to Report to Board of Directors
Juby
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Power Poster
Joined: Oct 2009
Posts: 3,927
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I'm pretty much the same, # filed, amount involved, basic information on the how.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius
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#1730221 - 08/13/12 05:28 PM
Re: SAR Summary to Report to Board of Directors
Juby
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Junior Member
Joined: May 2012
Posts: 46
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We only report total number filed by Violation Type and total dollars filed. We report quarterly and provide year to quarter data with the last three years of trending by month.
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Posts, thoughts, opinions and scenarios discussed are my own.
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#1730312 - 08/13/12 06:53 PM
Re: SAR Summary to Report to Board of Directors
Juby
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100 Club
Joined: Jul 2009
Posts: 218
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You have all been tremendously helpful. Thank you!
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#1730314 - 08/13/12 06:56 PM
Re: SAR Summary to Report to Board of Directors
Juby
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100 Club
Joined: May 2009
Posts: 234
hanging on by a thread
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We file electronically, and report the confirmation number we get back from the e-filing system, the type of activity (structuring, fruad, etc) and the dollar amount in a tabular format.
We started using the confirmation number to make it easier for auditors and examiners to match up board minutes to the actual SARs filed, and we've had no questions about our reporting since them.
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#1730333 - 08/13/12 07:16 PM
Re: SAR Summary to Report to Board of Directors
Juby
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Gold Star
Joined: Nov 2011
Posts: 402
USA
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Hm, that's a good idea. We use other grids to keep things organized, but your idea seems nice n' simple. Thanks for sharing.
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#1730908 - 08/15/12 10:59 AM
Re: SAR Summary to Report to Board of Directors
gacompliancegirl
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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We file electronically, and report the confirmation number we get back from the e-filing system... Very good idea. Alternatively, some banks assign a case number to every investigation. Some investigations turn into SARs, but many do not. Those that do are reported to the board using the case number. (Item 62 on the Form 111 allows the bank to insert the case number so examiners and auditors can compare SARs filed to SARs reported to the board.) Juby, In general, a good summary is no more than 2 or 3 sentences and would indicate whether the customer relationship continues. In circumstances where the board's fiduciary responsibilities are involved; e.g. insider abuse, embezzlement, etc. they are entitled to the details.
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#1730909 - 08/15/12 11:02 AM
Re: SAR Summary to Report to Board of Directors
Juby
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10K Club
Joined: Dec 2002
Posts: 40,766
Turnpike Exit 10
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We use the case number system and it works for us.
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Get your facts first, then you can distort them as you please. - Mark Twain
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