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#2114619 - 01/18/17 08:08 PM SAR Not filed form- anyone have a generic form?
djf1 Offline
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Joined: May 2015
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Regulators requesting that we be more consistent/neater with our format on documenting SARS not filed. Have checked with my banker friends and no one has a form that they use on SARS not filed. Have started a log of SARS not filed, but my handwritten notes are not working as a method of documentation. Can you share a form that has worked for you? thank you in advance for your assistance

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#2114627 - 01/18/17 08:22 PM Re: SAR Not filed form- anyone have a generic form? djf1
Doug Hendrickson Offline
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Doug Hendrickson
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Our Questionable Activity Report, that staff use to submit suspicious activity to us, has sections for:
Details of Questionable Transaction or Activity (staff)-includes date, account #'s, branch, etc.
Date Investigation Completed (BSA)
Investigation Results (BSA)
SAR Filed [Yes or No] (BSA)
Reason Not Filed (BSA)

I would suggest just creating a one-page Word document with those headings and use it yourself to document any SARs you didn't file. This would at least satisfy the format consistency request.
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#2114631 - 01/18/17 08:27 PM Re: SAR Not filed form- anyone have a generic form? djf1
bcompliance Offline
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Ditto what doug said. That is the exact process I used at my prior bank. Now it is a little different, but if we have something referred to us and we decide not to file, the process is the same as a filed SAR - except filing. We document the reason of concern, why it is not suspicious to us and then list SAR not filed in our log. We keep the documentation for 5 years.
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#2114633 - 01/18/17 08:34 PM Re: SAR Not filed form- anyone have a generic form? djf1
edAudit Offline
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edAudit
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You are here
I have heard of examiners looking for "SARS not filed" forms constantly. Pretty much any account or transaction that occurs in your bank without suspicious transactions would need such a form.

You may wish to have an accounts reviewed and no suspicious activity found form (questionable activity review) or any name that suits your liking.

Most I have seen is software generated as part of the BSA monitoring systems.

I would go with Doug's suggestion of a one page document.
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#2114727 - 01/19/17 05:29 PM Re: SAR Not filed form- anyone have a generic form? djf1
P*Q Offline

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P*Q
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Somewhere
Like others, we have a form the branches submit whereby on the bottom we have a box the compliance dept. completes on whether one was filed, etc. For internal decisions within Comp/BSA Dept, we do a memo, have not been criticized for either format.

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#2114888 - 01/20/17 03:26 PM Re: SAR Not filed form- anyone have a generic form? djf1
Oursisnottoreasonwhy Offline
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Oursisnottoreasonwhy
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Central Illinois

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#2114968 - 01/20/17 05:42 PM Re: SAR Not filed form- anyone have a generic form? djf1
Elwood P. Dowd Offline
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Elwood P. Dowd
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Next to Harvey
Quote:
my handwritten notes are not working as a method of documentation


They should. I think you have an examiner who's just looking for something to give you advice on. This pseudo requirement comes from a single sentence in the examination manual, not an actual regulatory requirement:

Banks should document SAR decisions, including the specific reason for filing or not filing a SAR.

There is no length or weight requirement and the "reason" should be pretty simple; e.g. no SAR will be filed because although:
* we have a suspect, the amount involved is less than $5,000;
* the amount involved is $18,000, we have no suspect; or
* the amount of the transaction was unusually large, upon investigation we determined that it represented the ordinary course of the customer's business and, therefore, it was not suspicious.

You have to deal with whatever they put in the written report. If it's a sidebar conversation, you don't need to take advice unless you agree with it.
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#2115224 - 01/23/17 10:35 PM Re: SAR Not filed form- anyone have a generic form? djf1
ACBbank Offline
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ACBbank
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New York City
I'm going to go out on a limb here and suggest that you do in fact document your non-SARs in a detailed manner. At my shop non-SARs are investigated as we would investigate a SAR. We use the same exact Investigation Summary Form and the only real difference is the disposition section where we indicate that the activity isn't suspicious and the justification for that line of thinking.
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#2115233 - 01/24/17 01:25 AM Re: SAR Not filed form- anyone have a generic form? ACBbank
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
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Next to Harvey
Sometimes, a little research could serve as the justification for a SAR filing when a lot of research on the same situation would have indicated it was unnecessary. My only comment was about the length of the reason why no SAR was not filed...
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