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#1883539 - 01/06/14 09:28 PM SAR Monthly Reporting to the Board of Directors
emelfe Offline
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Joined: Jan 2010
Posts: 3
We are having some discussion as to "how much" information should be provided to the board at their monthly meeting pertaining to the prior months SAR filings. Right now I provide a letter stating how many CTR's filed and how many SAR's filed, and how many of those SAR's filed resulted in an external or internal loss.

Is this the norm?

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#1883543 - 01/06/14 09:34 PM Re: SAR Monthly Reporting to the Board of Directors emelfe
Matt_B Offline
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I think, based on other discussions around here, that most boards get a short summary of the reason the SAR was filed as well. So, maybe: 2 SARs for structuring withdrawals, 1 for loan fraud. I think it's relevant for them to know what is going on, just not who it involves.
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#1883546 - 01/06/14 09:42 PM Re: SAR Monthly Reporting to the Board of Directors emelfe
Doug Hendrickson Offline
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I give them an extract from the spreadsheet I maintain that includes only the date, the reason and the dollar amount involved (both for this occurence and any continuing occurences).
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#1883548 - 01/06/14 09:46 PM Re: SAR Monthly Reporting to the Board of Directors emelfe
ACBbank Offline
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New York City
We do something similar to Doug, but include the total number of SAR filings and if/when LE has contacted the bank.
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#1883593 - 01/07/14 12:10 AM Re: SAR Monthly Reporting to the Board of Directors emelfe
rlcarey Online
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Joined: Jul 2001
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Galveston, TX
Dead horse - Google:

monthly sar report site:www.bankersonline.com
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#1883903 - 01/07/14 07:48 PM Re: SAR Monthly Reporting to the Board of Directors emelfe
WonderWoman Offline
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gone fishin'
I do a short sentence/summary & report Quarterly. I risk rate them as well.

High if we could take a loss/LE contact ...
Medium for multiple SARs & other riskier business ...
Low for the old cowboys who just don't want that darn govn't to know what they're doing with their own money.

I don't report any CTR or High/Med risk numbers until year end.
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#1884166 - 01/08/14 03:15 PM Re: SAR Monthly Reporting to the Board of Directors emelfe
Complycated Offline
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We had always reported the same sort of summary as mentioned above, but at our last FDIC exam we were written up for not providing enough detail to our board. Since then we have been required to report EVERYTHING from all SARs including names and all other details. No matter how much we fought the finding stuck. Has anyone else experienced this?

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#1884167 - 01/08/14 03:17 PM Re: SAR Monthly Reporting to the Board of Directors emelfe
rlcarey Online
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rlcarey
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Galveston, TX
Your FDIC examiners were sorely misinformed about the board reporting requirements.
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#1884463 - 01/09/14 12:05 PM Re: SAR Monthly Reporting to the Board of Directors emelfe
Elwood P. Dowd Offline
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Next to Harvey
As suggested, this field has been plowed several times here. From page 79 (document, not pdf) of the Manual.

Banks are required by the SAR regulations of their federal banking agency to notify the board of directors or an appropriate board committee that SARs have been filed. However, the regulations do not mandate a particular notification format and banks should have flexibility in structuring their format. Therefore, banks may, but are not required to, provide actual copies of SARs to the board of directors or a board committee. Alternatively, banks may opt to provide summaries, tables of SARs filed for specific violation types, or other forms of notification. Regardless of the notification format used by the bank, management should provide sufficient information on its SAR filings to the board of directors or an appropriate committee in order to fulfill its fiduciary duties.

Any examiner who wants to dictate how much is reported to the board is simply a non reader. This paragraph should have been called to his or her attention.

The last sentence is crucial in some circumstances. A bank that usually just reports a two sentence summary of each SAR without mentioning the subject's name cannot use that practice as an excuse for failing to give the board information about a situation that involves the board's fiduciary duties to the other shareholders. One example, not the only example, would be a defalcation where the bank incurs as loss. There are questions that board members should ask in these situations...
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#1884699 - 01/09/14 06:51 PM Re: SAR Monthly Reporting to the Board of Directors emelfe
WonderWoman Offline
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gone fishin'
If you can, I would find an examiner you trust to talk to about your cause for changing your practices. A knowledgable one would give you better advice and you can take that to senior management for further approval.
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#1884782 - 01/09/14 07:56 PM Re: SAR Monthly Reporting to the Board of Directors emelfe
NanaK Offline
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Joined: Aug 2013
Posts: 51
Near the water
This is a very serious topic for me. I know of Board Members at various banks who have talked about the SARs and the subjects of those SARs to the subject. I NEVER include names, but that is because of my experiences and this has been discussed with my current CEO. It makes it awfully precarious when you are in the habit of reporting names and then have to file on someone that may be sitting in your Board meetings...."why is the name left off of this one SAR?" FDIC knows exactly what happened in my case and I have never had a problem with any examiner because I do not include names on my reports to the Board. Even putting the informational prohibition blurb on your reports will not keep some from blabbing unfortunately. I also realize that when you are reporting on someone in executive management, for example, you can circumvent what you normally report to the Board and document that you met and discussed the situation with your audit chairman who is a Board member, for example.

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