Skip to content
BOL Conferences
Thread Options
#1855170 - 09/24/13 11:42 PM File A SAR. Then What?
Retread Offline
Power Poster
Retread
Joined: Oct 2003
Posts: 2,548
Southeast
Thought some of you might be interested in this article. You have to download it from the site, but don't worry. This isn't one of those sites that requires registration and it is bug free.

Maintaining Accounts After SAR Filings

There is also another one along the same lines.

Terminating a Relationship
_________________________
Politicians are like diapers. They need to be changed often and for the same reason.

Return to Top
BSA/AML/CIP/OFAC Forum
#1855292 - 09/25/13 03:38 PM Re: File A SAR. Then What? Retread
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
Reading this really ticked me off since the conclusion in the first document was basically to continue the relationship while working with law enforcement but in the real world how many times are we contacted by law enforcement after filing a SAR? In my case, almost never, which is why we have a policy of "3 SARs and you're out". I was hoping for a better conclusion to give me support when the account officers give me push-back when we tell them to close an account.

Return to Top
#1855333 - 09/25/13 04:23 PM Re: File A SAR. Then What? devsfan
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
The second article sort of concludes with a you're "damned if you do and "damned if you don't" terminate relationships with SAR subjects.

If it were written today, hopefully it would incorporate more than just court cases and reference some the things that DOJ and FinCEN have done in the interim to extract some financial retribution for consumers. I think those actions; e.g. a $500,000 DOJ bite out the First Bank of Delaware's carcass to reimburse consumers and the FinCEN director's very recent comments regarding TD Bank's failure to protect innocent consumers would tip the scales in favor of "damned if you don't."

File the SARs & close them. It's a zero sum game because they will simply go somewhere else, but when you find yourself dealing with people you actually believe are criminals, the only high ground is in making them move on.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#1855341 - 09/25/13 04:28 PM Re: File A SAR. Then What? Retread
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
I have to agree, Ken. I just can't see taking the risk (or continuing the expense) of keeping a questionable customer in the bank.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#1855397 - 09/25/13 06:10 PM Re: File A SAR. Then What? Retread
NanaK Offline
Member
Joined: Aug 2013
Posts: 51
Near the water
Thank you very much for posting this. I have an upcoming meeting where I will be begging for permission to close several accounts where we file repeat SARs. These articles along with the recent info on the whopping penalties on Saddle River Valley Bank and TD Bank and some other info that I have gathered will hopefully open some eyes. It's a shame that I have to go in with guns loaded and a bunch of scary information hoping someone will listen. I do not want to wait for some examiner to announce an ugly CMP because we did or didn't do A, B and/or C. Grrrr.

Return to Top
#1855457 - 09/25/13 07:34 PM Re: File A SAR. Then What? NanaK
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Make your recommendations in writing & put them (and the response) in the file with everything else. ("Home copies" are always good.) If they won't take your advice, just let go of it and go on to what's next. Don't fixate, there's plenty of other stuff to do. wink
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#1855587 - 09/25/13 09:57 PM Re: File A SAR. Then What? Retread
NanaK Offline
Member
Joined: Aug 2013
Posts: 51
Near the water
Thanks, Ken. Gosh, but fixating is so fun sometimes.

Return to Top

Moderator:  Andy_Z