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#1817691 - 05/28/13 01:42 PM SAR on Directors
n2compliance Offline
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n2compliance
Joined: May 2011
Posts: 102
Is a bank required to file a SAR if it loses more than $100,000 on a loan to a director? Even if there is no suspicious activity? We're being told that it is a requirement.

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#1817705 - 05/28/13 02:07 PM Re: SAR on Directors n2compliance
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Ask your source for a citation. Absent insider abuse, which you did not allege, there is no different SAR filing threshold for directors. If there was loan fraud or something else, you would file for that reason, not because he or she was a director.

There should be other ramifications...they may outweigh the impact of a simple SAR filing.
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#1817723 - 05/28/13 02:45 PM Re: SAR on Directors n2compliance
Ted Dreyer Offline
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Ted Dreyer
Joined: Apr 2001
Posts: 2,245
Quote:
We're being told that it is a requirement.


A requirement that you file a Suspicious Activity Report when there has been no suspicious activity? If they even attempt to justify that, please post their rationale here so that we can see it.

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#1818481 - 05/30/13 12:03 PM Re: SAR on Directors n2compliance
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 77,591
Galveston, TX
Of course, I do hope you are referring to a now ex-director smile
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