How many FI's give their Board Members more information than just the number of SAR's filed or renewed? I have examiners who are strongly suggesting that we share more information about the subjects of the SAR with the Board. Our stance has been that unless we thought the account was going bad we would not share all of the details.

All information is appreciated.

We share how many SARs, what the SAR reason was, possibly details of what the activity was, the dollar amount involved, and whether or not there was a loss to the bank. If a board member wants to know who the SAR subject was, we ask them to discuss it with us privately after the board meeting, one-on-one. Some of our board members attend via conference call, and we have no idea if they have anyone else within earshot. We also just try to keep the information to the bare minimum of people with knowledge of the SAR subject.

Frankly, your examiner does not know what they are talking about. Best practice is to not disclose subject due to SAR confidentiality provisions. Examiners cannot write you up for not doing that. Stand your ground.

a suggestion from an examiner is simply that, a suggestion. the bank does not need to take action on suggestions. kindly thank him for his suggestion and move on.

I strongly agree with McFly and Happy - there is no requirement to provide full information about the subjects of a SAR. Off the top of my head, here are some things you can do in your discussions with the examiners:

1) Ask them for a citation on this, which they won't be able to provide.

2) Remind them of the FIN-2012-A002 which talks about how SAR disclosure by directors has been a problem in the past, and then explain how your process mitigates the risk of SAR disclosure. Fin-2012-A002 can be found here: https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2012-a002

3) Explain that providing subject information can be problematic if a director is ever the subject of a SAR. Here is an article were I explain the challenges with this: https://www.compliancecohort.com/blog/board-reporting-on-director

4) Now, I'm wondering if the examiners are concerned from a Safety & Soundness perspective in that a director approving a loan should know if the bank has other concerns, such as knowledge or suspicion of illegal activity. In that case, you can set up a SAR committee that involves your President who will be at board meetings and could bring up such information if the need ever came up. Here is a short video where I discuss the safety & soundness concern of providing subject information to directors: https://www.compliancecohort.com/blog/reporting-sars-to-the-board-of-directors

5) If all else fails and they still recommend this - or worse, include it in the report - I would work this up the chain of command before I agree to implement this frivolous recommendation.

You've got some awesome and correct direction from those who have posted. I can't really add to it other than say you are getting great advice at no cost.