How important is it to have a log of sar activity? I was asked if a copy of the sar and the information gathered or just the information gathered if not filed is sufficient. My argument is that the log will show the date rec'd, date it was determined to be suspicious, and the date filed for tracking.

OK, I'll bite. I'm not in favor of a SAR log unless you file so many that you need a log to keep track of them. The more documentation you create relating to SARs the more difficult it is to keep the SAR confidential.

I have found it helpful to keep a comment sheet in the front of each file containing an SAR. This way you not only can log the dates for each step you took in the determination and filing of the SAR, but you can also refresh your memory if questions ever arise about the situation. This can also be helpful in the event that your bank decides not to file the SAR. If there is ever a question as to why you determined that filing wasn't necessary, your comment sheet would spell it all out for you.

I'm confused. Potential problems that might need to have a SAR filed shouldn't be kept with SAR's that have been files. Since all of the information gathered becomes part of the SAR after filing, why would you want to have privacy issues by itermingling information that has not had a SAR filed?

I not only handle compliance issues but also internal auditing. That being said, for auditing purposes I also have to research for potentially suspicious activity that was not reported on an SAR. It is helpful for me to keep, in my personal files, information of that sort to allow me to determine that the bank is maintaining due diligence in the Bank Secrecy area.

I decided to create a SAR log about a year ago. I have found the log useful in monitoring destruction time frames and reminding me of the SAR subject accounts that need to be reviewed periodically. The log is secured in a file along with my SAR records.