I would like to hear your opinions regarding 314(b) Information Sharing. I have been with this bank a little over a year and presently our bank is not registered for 314(b). What are your opinions of whether a bank should be registered.

I think it's a good idea to be registered. It's easy to do, lasts for a one year period, and you never know when a sitatuion might lend itself to it being useful.

We've registered for years because the person who was the contact prior to me coming to this Bank always had. I renew it every year and every year I say I'm not going to because in my 5 years here, I have not contacted anyone else nor have I been contacted so I've thought of not renewing so it's one less annual thing I need to remember to do. That's my two cents.

I'm not certain why any banks stay registered continuously. Registration is quick and easy and could readily be done on an "as needed" basis. The foundation piece is that a bank should definitely address the issue in its BSA policy and incorporate the safeguards spelled out in the examination handbook "just in case" it should choose to register at some point. The board should say grace over the possibility.

The new SAR report allows for "joint" filings between multiple instittuions. Obviously, information sharing between banks assumes 314(b) registration by all concerned.

It is addressed in our BSA Policy that we are not registered. I am to decide whether to register or keep it as is. Thanks for your advice and comments.

Just a suggestion, revise your policy to say that you are empowered to register at your discretion, but you will notify the board at its next following meeting if you do so. There will be times when sharing is appropriate if not essential, but this is not something done lightly.

Being a European perhaps it is a cultural difference but the sharing of information even if it only happens once, is surely a good thing in our area of business?

I think one of the recommendations from the 9/11 Commision Report commented on the fact that one of the possible causes to 9/11 was a lack of information sharing.

If its quick and easy to do then my personal opinion is that it should be done.

I see no downside to registering and renewing annually. You are not forced to use it but it is ready when and if you are. Also, you never know if you will get helpful information if you ever receive a request from another registered user and you would not be able to if you were not registered.