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#1730121 - 08/13/12 03:28 PM SAR Summary to Report to Board of Directors
Juby Offline
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Posts: 218
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
AFaquir Offline
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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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#1730133 - 08/13/12 03:42 PM Re: SAR Summary to Report to Board of Directors Juby
KTW327 Offline
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In our summary to the Board, we include the facts (suspicious activity, dates, and dollar amounts) surrounding the SAR, the dollar amount of any loss (if we took one), what action we took, and if it is a continuing SAR or not. We try to cut any unnecessary statements and also do not include the name of the "suspect" in the SAR. If we ever had to file on an insider, we wouldn't want it to seem strange that a SAR was being reported with no name, if that was our practice. By omitting the name- you no longer have to worry.

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#1730138 - 08/13/12 03:46 PM Re: SAR Summary to Report to Board of Directors Juby
#Just Jay Offline
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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
E.E.G.B Offline
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Originally Posted By: Just Jay
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
Doug Hendrickson Offline
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I'm pretty much the same, # filed, amount involved, basic information on the how.
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#1730180 - 08/13/12 04:33 PM Re: SAR Summary to Report to Board of Directors Juby
JacF Offline

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Like AFaquir, I use a number system when reporting to the board. I also include some of the common summary information mentioned previously. It basically looks like this:

SAR # 2012-005
Filed: April 1, 2012
Activity: March 7, 2012 to March 21, 2012
Type: Check fraud, ID theft
Amount: $25,000
Loss: none

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#1730221 - 08/13/12 05:28 PM Re: SAR Summary to Report to Board of Directors Juby
amlzed Offline
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Joined: May 2012
Posts: 46
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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#1730312 - 08/13/12 06:53 PM Re: SAR Summary to Report to Board of Directors Juby
Juby Offline
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Posts: 218
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
gacompliancegirl Offline
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hanging on by a thread
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
BFrame Offline
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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
Elwood P. Dowd Offline
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Next to Harvey
Quote:
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
Retired DQ Offline
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Turnpike Exit 10
We use the case number system and it works for us.
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