If 20 years of surviving banking exams has taught me anything, it is to always be thinking up the weirdest possible loopholes and angles so as to anticipate whatever my examiners are going to come up with next time they visit.

So as I'm deleting SARs today from August 2016, I notice that one of the customers there is someone whose activity triggered SARs that lasted from August 2016 to January 2020. Here's the weird angle I'm picturing:

Could an examiner reasonably say that since I filed a SAR on this customer in January 2020, then the August 2016 SAR is part of that January 2020 record, and can't be or shouldn't be deleted until 5 years after January 2020?

So far I've been purging SARs based on date of filing plus 5 years. I know there is no legal requirement to keep them beyond that period even if subsequent SARs were filed on the same person. As my finger hovers over the delete button here, I'm just wondering if anyone has had an auditor or examiner claim otherwise.

We purge/destroy five years from filing date. So in your case, I would shred the August 2016 one.

I know this is beside the point, but why did you keep this customer for 5 years while you continued to file SARs on them?

OhSoAnon (OP) here: Agreed, that's a separate discussion from way before I started here. Although your question is valid, I'd like to keep this thread focused on the question I asked.

FFIEC BSA/AML Examination Manual - Appendix P: BSA Record Retention Requirements

Suspicious Activity Report and Supporting Documentation

A bank must maintain a record of any SAR filed and the original or business record equivalent of any supporting documentation for a period of five years from the date of filing.