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#1789609 - 02/27/13 03:50 PM SARs - to discuss with account officers or not
Tryin-2-Comply Offline
100 Club
Joined: Apr 2003
Posts: 202
Hills of TN
We have some SAR filings that have been repetitive - we escalated that to our Executive Mgt with recommendations on closing the relationships. One of our account officers who oversees one of the relationships learned of this recommendation and is upset with my department. I've never discussed filings with account officers/ relationship managers - fear of them discussing improperly with the customer.

How do others handle this???

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#1789624 - 02/27/13 04:00 PM Re: SARs - to discuss with account officers or not Tryin-2-Comply
BFrame Offline
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BFrame
Joined: Nov 2011
Posts: 401
USA
I have never disclosed a SAR filing to an officer/relationship manager. They are the closest to the customer & things do slip in conversation (or may be stated intentionally to give the customer a head's up), esp. when a customer has a significant relationship with the bank.

You stated that "one of our account officers ... learned of this recommendation." Did they learn of the SAR? Or just the recommendation to close the account?

If the officer only knows about the recommendation to close the account, I wouldn't be as concerned about that.
But if someone told an account officer that a SAR was filed, that's another issue. Someone with confidential information is spilling the beans.
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#1789625 - 02/27/13 03:59 PM Re: SARs - to discuss with account officers or not Tryin-2-Comply
Dani York, CRCM Offline
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Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
Generally, I tell them in every training session that I will interview them for SAR investigations, but I will NEVER tell them if a SAR was filed or not, for their protection. The one time I did have a SAR filing that resulted in a closure, the officer was very upset and felt that they didn't have the ability to defend the customer. I told them it was management's call and that the bank just couldn't take the risk associated with the type of activity going on in the acocunt hurting us during an exam. (I did not tell the officer about the SAR, just the decision to close the account) Fortunately for me, the next day we got serve with a GJS on that customer. The serving officer served it at that officer's branch. After that, he finally understood the severity of the issues and why we decided to close the relationship based on the activity.

You may not be as fortunate to have some "proof" for your officer, but feel free to use my story. The officer needs to understand that it's not about you or your department just wanting to toss customers, but that your department is trying to protect the bank from criticism and fines, and some of the bank's customers expose the bank a little too much for comfort.

You can also throw out there that had he been more helpful in the investigation, it may not have gotten to the point of closure in the first place (ie he could have called and gotten more info and offered some insight in to why the activity was legitimate and didn't warrant a SAR).
Last edited by Dani York, CRCM; 02/27/13 04:02 PM. Reason: Clarify that the officer did not know about the SAR just the closure decision
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#1789645 - 02/27/13 04:20 PM Re: SARs - to discuss with account officers or not Tryin-2-Comply
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,159
New York City
Any time that I recommended an account be closed, I gave the account officer a heads up as a courtesy. In my old bank, Management would sometimes call the AO and question them about the customer and activity. If not prepared, they would be completely blindsided. I found that little bit of courtesy goes a long way in getting their assistance with future customers.

However, I would not discuss an SAR without anyone outside of the BSA Department or management.
Last edited by ACBbank; 02/27/13 04:20 PM.
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#1789647 - 02/27/13 04:20 PM Re: SARs - to discuss with account officers or not Tryin-2-Comply
Tryin-2-Comply Offline
100 Club
Joined: Apr 2003
Posts: 202
Hills of TN
thank you for the comments....

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#1789738 - 02/27/13 06:32 PM Re: SARs - to discuss with account officers or not Tryin-2-Comply
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Depending on the circumstances, an account officer may need to know about the bank's concerns. They never need to know about the SAR.
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#1789808 - 02/27/13 08:00 PM Re: SARs - to discuss with account officers or not Tryin-2-Comply
WonderWoman Offline
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WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
To repeat what everyone else is saying ...

I always warn my officers in my training - that when I start asking them questions about a customer or an account - that is their "heads up" that "Something Ain't Right". & that if I do not get a reasonable explanation - over time, it may require account closure.

That way they can't say they were blindsided (well they can say it - but it doesn't have any merit).

I never disclose if a SAR was filed or not.
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My opinions are my own, and not that of my employer.

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