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.