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#1940510 - 07/14/14 05:58 PM frequency of SAR reporting to board ?
Chocaholic Offline
Gold Star
Joined: Aug 2005
Posts: 443
Northwest
OK, BSA is not my primary thing so when asked the question, I did some research but could not find anything to support what I thought the rule was... namely you must inform the board of a SAR filing at the next scheduled Board meeting. Is this still correct, and if yes where can I find the info./site?

2nd part to question, we currently run most SAR filings through our Board Audit Committee -meeting schedule is quarterly, audit chair discusses at next board meeting usually following day. Is this frequently enough or must we report to Board monthly and then could provide summary data to AC at their quarterly meeting?

I think what we are doing has not been criticized but I remain confused and any help would be appreciated.

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#1940557 - 07/14/14 06:43 PM Re: frequency of SAR reporting to board ? Chocaholic
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,348
New York City
I have seen some banks due it monthly and others do it quarterly. It depends on a number of factors.
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#1940627 - 07/14/14 07:58 PM Re: frequency of SAR reporting to board ? Chocaholic
PeeWee Offline
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Joined: Aug 2007
Posts: 254
Chocaholic - the inforamtion in the FFIEC BSA Exam manual may be what you are looking for:

http://www.ffiec.gov/bsa_aml_infobase/documents/BSA_AML_Man_2010.pdf

Notifying Board of Directors of SAR Filings
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.
Last edited by PeeWee; 07/14/14 07:58 PM.
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#1941917 - 07/17/14 11:07 AM Re: frequency of SAR reporting to board ? Chocaholic
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
The regulation you are trying to follow comes from your regulatory agency, not BSA. It says you must report SARs to the board "promptly." Obviously, that time frame, like "beauty," lies in the eyes of the beholder.

I've seen banks criticized in their written report of examination for reporting to the board on a quarterly basis. If there is a standard expectation it would probably be that they should be reported in the next regularly scheduled board meeting in the month following the month when the SAR is filed.
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