A government agency is requesting information relating to a SAR filing regarding a customer (and former employee) of the bank. They are wanting the SAR and all bank documentation relating to the investigation.

I know the definition of "financial records" under RFPA is very borad. Would this information be considered the financial records of the customer or records of the bank?

Thanks

WHICH government agency?

OCC

If the OCC is your primary regulator they have full and unlimited access to all bank records, SAR related or not - period.

Per rlcarey's comment, see RFPA section 3413 (b) & possibly (l).

Thanks guys.