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#628912 - 10/25/06 01:32 PM SARs & Imaging - question
CantBeShocked Offline
Gold Star
Joined: Apr 2006
Posts: 260
We have a great in-house imaging system and are considering imaging our SARs and all supporting documentation into a private folder that only the BSA Department could access.

Is anyone doing this ? If so, how did you address any security issues? I am concerned about hackers (if one every got in) or the security "dropping" mysteriously and then other employees seeing our folders.

Any insight will help. Thanks !

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#628913 - 10/25/06 02:20 PM Re: SARs & Imaging - question
Pinkie CRCM Offline
Gold Star
Joined: Aug 2003
Posts: 399
My first thought is how are you filing your SARs? I recently got setup with the BSA e-filing website and it's wonderful. I get confirmation and can keep an electronic copy of my SAR that is not in .pdf format (you have to download a special viewer - it's FREE - and not everone has it.)

We have a similar operation with our Internal Audit and Risk Mgmt depts. Those network "folders" have restricted access.

Two controls to think about:
1. make sure you test annually "who has access to what" to make sure all security is set the way it should be and
2. you must ensure that any changes of access to the folders are signed off by the BSA Department manager.

You could even try to have them passworded as well.

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#628914 - 10/26/06 01:15 PM Re: SARs & Imaging - question
LauraL Offline
Gold Star
Joined: Jun 2005
Posts: 365
I have all my SARs and supporting documentation scanned. Only, me - BSA Officer, President, and Vice President have access to the scan folder. It has worked out great for us and I had no complaints from FDIC when they were here in May 2006.
"I'd rather be running a marathon than doing compliance!"

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#628915 - 10/30/06 09:02 PM Re: SARs & Imaging - question
Rangers Fan Offline
Gold Star
Rangers Fan
Joined: Dec 2001
Posts: 345
In the BSA E-filing product, you can also restrict who has access to view, etc. I heard from an examiner that electronic submission would eventually be required so the issue of having paper submissions locked up should be just as easily replaced by restricted electronic files. My only concern is that even though those files are restricted, your IT folks will always have access to those as well and what if you have an issue that deals with someone in their department? It sounds crazy, but I have had just such a scenario. Obviously this one was a paper-file job, but those concerns are still out there. Ah, gotta love BSA!

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