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#1780107 - 01/25/13 10:55 PM Decision not to File a SAR
UTBPMOM Offline
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Joined: Sep 2005
Posts: 73
Where can I find the requirement on how long to retain documentation when we decide not to file a SAR?

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#1780110 - 01/25/13 10:58 PM Re: Decision not to File a SAR UTBPMOM
Doug Hendrickson Offline
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Doug Hendrickson
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I don't believe I've ever seen such a requirement for a non-filing. However, we keep ours at least from one BSA examination to the next, as they always ask for the documentation on the times that we chose not to file a SAR.
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#1780116 - 01/25/13 11:21 PM Re: Decision not to File a SAR UTBPMOM
WonderWoman Offline
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WonderWoman
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gone fishin'
I keep mine 5 years.
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#1780117 - 01/25/13 11:23 PM Re: Decision not to File a SAR WonderWoman
Doug Hendrickson Offline
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Doug Hendrickson
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Is that because of a regulatory requirement or just an 'abundance of caution (LOL)'? I didn't think that it would fall under the 5 year rule.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1780137 - 01/26/13 10:48 AM Re: Decision not to File a SAR Doug Hendrickson
Elwood P. Dowd Offline
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Elwood P. Dowd
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Next to Harvey
From one examination to the next should suffice; there is no record retention requirement.
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#1780150 - 01/26/13 03:35 PM Re: Decision not to File a SAR UTBPMOM
rlcarey Online
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Galveston, TX
Unless the regulators think that you have missed some SARs and order a look back. Having records of what was actually reviewed and what was not reviewed may help narrow the scope of such an enforcement order. But otherwise, I agree with the above comments.
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#1780163 - 01/27/13 03:35 PM Re: Decision not to File a SAR UTBPMOM
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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I do agree with Randy that if the bank's process is called into question, evidence of what was reviewed and how decisions were reached can limit (or eliminate the need for) the scope of a lookback. A lookback can easily extend farther back than the prior examination.
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#1780206 - 01/28/13 02:56 PM Re: Decision not to File a SAR UTBPMOM
John Burnett Offline
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John Burnett
Joined: Oct 2000
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Cape Cod
Just such a look-back is involved in the $10 million CMP we reported in today's Top Stories. Here's a separate thread with some thoughts on that enforcement action.
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#1780432 - 01/28/13 08:18 PM Re: Decision not to File a SAR UTBPMOM
UTBPMOM Offline
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Joined: Sep 2005
Posts: 73
Thank you all for your input.

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