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#65369 - 03/05/03 01:48 PM Two SAR Questions
SteveG Offline
Joined: Jul 2001
Posts: 58
Which Board of Directors can be informed that a SAR has been filed ... only the Board of the filing entity or also its holding company or parent board? And ... if affiliates share a security officer, are you okay with the fact that, by definition, once the security officer knows of a SAR by one entity, that entity's affiliates know of the SAR filing. Thanks for your thoughts.

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#65370 - 03/05/03 07:09 PM Re: Two SAR Questions
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,868
Cape Cod
I believe you should keep the notification "in house." Sharing it with an affiliate's board may violate the rules, and it definitely provides more chances for the information to leak outside the "family."

As for the busy security officer, he or she should limit any discussion about the SAR to those persons within the reporting institution who need to participate in or know about the SAR. In other words, the security officer needs to know which information can be shared with which groups of people.

This information should not be exchanged except for sharing institutions under 314(b) of USAPA.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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