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#1826914 - 06/24/13 10:04 PM 90 Day Continuing SAR - Missed Filing
ItNeverEnds CRCM Offline
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Looking for my sanity
Hello all,

So I have a bit of a problem. I went to start work on a continuing SAR and realized that the last one did not get filed. I completed the SAR and thought that I uploaded it, but apparently I didn't. Not an excuse, but I was going out for surgery that had me pretty messed up mentally, anyway, somehow I either didn't upload the SAR or there was some sort of error when I uploaded it(?) and I didn't realize it. At this point, anything is possible as I was in a pretty bad mental state at the time (dealing with a new cancer diagnosis). The SAR was supposed to be filed in March and I didn't realize that it hadn't until today when I went to work on the June continuing activity. Any thoughts on what I need to do? Do I go ahead and file the March and the June one? With a note in the March one of the fact that it was missed? Never done anything this stupid before, so I'm kind of lost as to what to do. Thanks in advance!
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#1826922 - 06/24/13 10:32 PM Re: 90 Day Continuing SAR - Missed Filing ItNeverEnds CRCM
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,215
Galveston, TX
I would file one SAR now covering the Jan thru current date and document the file, acknowledging the error. There really isn't anything else you can do at this point. The water has passed this bridge.

P.S. Make sure management and the board are aware of what happened. These are not the sort of surprises they probably like to get from the regulators.
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#1826923 - 06/24/13 10:41 PM Re: 90 Day Continuing SAR - Missed Filing ItNeverEnds CRCM
ItNeverEnds CRCM Offline
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Looking for my sanity
Thanks Randy. I know there's no way to "fix" it, just wasn't sure what to do going forward. Yes, I plan on informing the Board tomorrow at the Board meeting. I figure I'll hear from the Regulators that we need alternate plans/back up for when the BSA Officer is gone, which is no surprise and I agree, but we're just a small 7 year old bank, so still a pretty small staff. I thought I had everything taken care of before I left, but I guess I screwed up. Never had a finding on any regulatory BSA exam before, I guess there's always a first.
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#1826926 - 06/24/13 10:43 PM Re: 90 Day Continuing SAR - Missed Filing ItNeverEnds CRCM
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
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While we don't like to make mistakes, unless this is some major money laundering ring, don't beat yourself up too badly. I have seen banks make much bigger mistakes than this and everyone lives to see another day.
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#1826928 - 06/24/13 10:55 PM Re: 90 Day Continuing SAR - Missed Filing ItNeverEnds CRCM
ItNeverEnds CRCM Offline
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Looking for my sanity
Thanks Kathleen. I hate making mistakes, especially something like this which can't be fixed, and I have no one to blame but myself. Hopefully this is the only stupid thing I did/missed. Never thought I'd be dealing with stage III cancer at 40, it definitely messed with me for awhile. Hopefully I can keep it together and not forget something else for another couple of months until I finish my treatments.
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#1826931 - 06/24/13 10:56 PM Re: 90 Day Continuing SAR - Missed Filing ItNeverEnds CRCM
Kathleen O. Blanchard Offline

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And best of luck to you. Especially with something like that on your mind, there should be some back ups for you. You don't have to carry the weight of the world around.
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#1827279 - 06/25/13 06:22 PM Re: 90 Day Continuing SAR - Missed Filing Kathleen O. Blanchard
ItNeverEnds CRCM Offline
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Looking for my sanity

Originally Posted By: Kathleen B
And best of luck to you. Especially with something like that on your mind, there should be some back ups for you. You don't have to carry the weight of the world around.


Thanks Kathleen. I am halfway through my last round of treatment (chemo - not a lot of fun) and working mostly full time. Although I had to laugh. Let's see, I'm the Risk & Compliance Officer, BSA Officer, Security Officer, Information Security Officer, Fraud Investigator and a whole host of other things. So sometimes I do feel I am carrying the weight of the world. It just goes along with working for a start up bank.
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#1827344 - 06/25/13 07:02 PM Re: 90 Day Continuing SAR - Missed Filing ItNeverEnds CRCM
NotDoneYet Offline
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NotDoneYet
Joined: Jul 2010
Posts: 482
PA
I missed a 90 day follow-up, too, a couple years ago. I didn't realize it until the regulators found it. It was with the start of using e-filing and I didn't hit submit. It didn't end up being as unforgivable as I expected. My own disappointment was harder to deal with than their reaction.
Just do your best and put your focus back on your well-being.

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#1827355 - 06/25/13 07:10 PM Re: 90 Day Continuing SAR - Missed Filing ItNeverEnds CRCM
NotDoneYet Offline
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NotDoneYet
Joined: Jul 2010
Posts: 482
PA
I guess I should have told you how I resolved it and it was considered acceptable in 2011. I submitted it without changing any dates and sent an email to FinCEN Help Desk to let them know, with an apology for missing it. They sent back a nice reply that I had done the right thing and gave me a reference number should there be any further questions.

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#1827450 - 06/25/13 08:43 PM Re: 90 Day Continuing SAR - Missed Filing ItNeverEnds CRCM
ItNeverEnds CRCM Offline
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Looking for my sanity
Thanks NotDoneYet. Glad to know I'm not the only one that did this. The week I thought I filed it was the worst week ever, it was my last week of work prior to my surgery to remove the tumor, so I was stressed about surgery, about being off work for 1-2 months and on top of that I had my external BSA audit that week. It was a nightmare week. I barely survived with my sanity intact!
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#1827472 - 06/25/13 09:06 PM Re: 90 Day Continuing SAR - Missed Filing ItNeverEnds CRCM
edAudit Offline
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edAudit
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You are here
Sorry to hear (I am sure that you heard this before) but it is only a job. Your health is more important than the stress.
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#1827539 - 06/25/13 10:21 PM Re: 90 Day Continuing SAR - Missed Filing ItNeverEnds CRCM
ItNeverEnds CRCM Offline
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Joined: Oct 2006
Posts: 992
Looking for my sanity
Thanks EdAudit. Yes, I hear this and I do believe that, but it's hard to keep in that mindset. I've worked hard to get where I'm at and I don't like to let others down (or myself). It's been a roller coaster of a journey for sure, not one I would have chosen to ride, but I'm on it nonetheless.

Thanks again to everyone.
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"The reason I talk to myself is because I'm the only one whose answers I accept."
- George Carlin

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#1827876 - 06/26/13 05:26 PM Re: 90 Day Continuing SAR - Missed Filing ItNeverEnds CRCM
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,333
Cape Cod
I do think that you owe it to yourself and to your employer to try to get some support in place so that you are not stretched so thin. Work stress can be a real negative when you're fighting back from a major health incident. And that won't help job performance, either.
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BankersOnline.com
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#1827911 - 06/26/13 06:08 PM Re: 90 Day Continuing SAR - Missed Filing ItNeverEnds CRCM
Indy Banker Offline
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Joined: Aug 2010
Posts: 528
Amen to what John B said. Do everything you can to take care of yourself both physically and mentally to keep yourself strong. This is a time of life not to stress over the small stuff. It's all about perspective. My wife works in an Emergency Room - when they have a bad day at the office, someone lost a life. I'm in Compliance - what's a bad day there - a Loan Officer didn't disclose a GFE on time? An APR was under-disclosed? Missed a SAR filng? OOPS Not in any way making light of what we do and it is a tremendously important and difficult job these days, but you have to do your absolute best and keep it all in perspective. Stay positive - stay strong. God bless and good luck to you!

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