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#450329 - 10/31/05 10:41 PM Audit Committee Meetings
CrashDavis Offline
Gold Star
Joined: Jun 2005
Posts: 283
I have a question regarding what information you are providing your Audit Committee. This pertains to Suspicious Activity Reports. We presently give the committee only general information. 1. Type of SAR
2. Amount 3. Location occurred.

The committee is wanting us to provide names. We have told them we cannot. Are we correct in this.

Another question is does your bank have a representative of corporate counsel present at Audit Committee meetings? If so, is it every meeting.

Thanks for your help.

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#450330 - 10/31/05 10:51 PM Re: Audit Committee Meetings

Okay, we had this same issue of curiosity and our approach was to change our BSA policy to have the SAR info disclosed this way:bare minimum-why, where, loss or not-the end. If a member wanted more info, they needed to approach the compliance or BSA officer after the meeting to get info if they couldn't sleep at night, but with the reminder that they weren't provided the info for their protection and the safe harbor and that if they knew and it was ever shared outside the bank, they would be "on the list" since they were privy to the info and could be held personally liable. This approach may or may not work, depending on the group of personalities that you have to work with. Good luck, but if they ask and are persistent, you need to save yourself and provide info, just CYA and document well.

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#450331 - 10/31/05 11:05 PM Re: Audit Committee Meetings

Regarding giving SAR info to the Audit Committee of the board of directors. There is no law or regulation prohibiting it. Many commenters think it is not a good idea because they don't trust their directors to keep the info confidential. From my experience as a consultant to many small banks, most did give all info to the directors. Examiners never criticized this to my knowledge. I never heard of a case where a director disclosed the info.

Regarding corporate counsel, most small banks never had corporate counsel at audit committee meetings, or only on rare occasions when it was known ahead of time that their opinion would be needed. Only time I saw it done was when the small bank actually had a full-time bank attorney on staff, which is rare for a small bank.

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#450332 - 11/01/05 12:20 AM Re: Audit Committee Meetings
Andy_Z Offline
10K Club
Joined: Oct 2000
Posts: 27,542
On the Net
I agree with Anon. I know Ken Golliher believes you need not/should not, but in my experience as a small banker, if I were a director and had liability here, I'd want to know details on what was happening.

But it is your bank's call.
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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#450333 - 11/03/05 08:07 PM Re: Audit Committee Meetings
Czargazer Offline
Gold Star
Joined: May 2003
Posts: 298
Pacific Northwest
Coming from a medium sized bank (3 Billion), we share the actual SARs with the Audit Committee of the BoD as a part of each meeting. Reports are distributed along with the rest of the package we send to them before each meeting. This has been our practice for many years and has never faced criticism from examiners or external auditors.
Everyone has to make a living, mine just happens to involve thumbscrews.

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#450334 - 11/10/05 04:13 PM Re: Audit Committee Meetings
K8T Offline
100 Club
Joined: Sep 2003
Posts: 196
I have fallen down the rabbit ...
We report the SAR activity on a quarterly report to the Board. We will report to the Executive Committee on a weekly basis if needed, but only with general terms, as stated above, we don't include names as a general rule. The BSA officer which is also General Council reports the filings and any cases we've investigated but not filed.
Some days, it is all a mystery to me.

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