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#1920538 - 05/06/14 09:11 PM regulatory citation
DoS Offline
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I am having trouble finding the actual citation for the requirement to report SAR's to the Board of Directors. I know that it has to be done but I want to head off a future argument. Anyone know?
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#1920545 - 05/06/14 09:23 PM Re: regulatory citation DoS
Matt_B Offline
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I believe every regulatory agency has their own specific guidance on this, and as far as I know they all specify that SARs should be reported to the Board "promptly" which is generally taken to mean the next scheduled board meeting. If you search: SAR Notification to Board and your regulator, you'll likely get your answer.

For some samples:
https://www.bankersonline.com/forum/ubbthreads.php?ubb=showflat&Number=97558
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#1920555 - 05/06/14 09:44 PM Re: regulatory citation Matt_B
Elwood P. Dowd Offline
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Quote:
...every regulatory agency has their own specific guidance on this...


That's correct. DoS is from an OCC supervised institution and the thread you linked includes the correct citation.
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#1920557 - 05/06/14 09:46 PM Re: regulatory citation DoS
DoS Offline
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Perfect, thanks guys! I searched for that for a while!
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#1920569 - 05/06/14 10:12 PM Re: regulatory citation DoS
Elwood P. Dowd Offline
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Most people would naturally assume that board reporting was part of the BSA regulation.

However, if you think about it, why on earth would FinCEN want SAR filings reported to the Board? As one of the ABA's more crispy comment letters pointed out, reporting SARs to the board is "counterintuitive" and acts as an upward delegation of responsibility after the fact.

Clearly, that's the regulatory agencies' forte.
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