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#8051 - 12/19/01 07:41 PM SAR Reporting to Board
La. Lady Offline
Diamond Poster
La. Lady
Joined: May 2001
Posts: 1,873
When reporting to the Board of Directors that a suspicious activity report was filed, do you give the NAME of the person or business that the report was filed on. My report is made in writing to the Board of Directors. I always give the nature of the suspicion, but never the name on the report. The only person going into the meeting knowing the name is the Bank President. I am sure that he give out the name if asked.. But I am wondering if the rest of you release the name in writing....

Thanks

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#8052 - 12/19/01 07:59 PM Re: SAR Reporting to Board
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,798
Cape Cod
I make a point of not releasing the name at the board meeting. I explained this to the directors by discussing the non-disclosure rules for SARs and told them I didn't want a name recorded in the minutes, which might be subpoenaed for other reasons.

I also told them that if they didn't know the name, they couldn't slip and mention the SAR at an inappropriate time or place.

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#8053 - 12/19/01 08:02 PM Re: SAR Reporting to Board
SMQ, CRCM Offline
Power Poster
SMQ, CRCM
Joined: Apr 2001
Posts: 4,828
Between the lines
Absolutely not!! I explain the circumstances and the amount of the loss to the bank, if any.

BUT, as you know, to every "absolute" there is an exception. If the SAR were on an employee or ex-employee, the board would already be familiar with the situation and then the name would probably be mentioned in the meeting, but not in the written report to the board. As you recall, you have to file a SAR on an employee for any amount.

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Opinions expressed are not necessarily those of my employer.

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#8054 - 12/19/01 08:35 PM Re: SAR Reporting to Board
NancyF Offline
100 Club
NancyF
Joined: Dec 2001
Posts: 173
PA
I give the Board a copy of the SAR, however the customer name is not documented in the minutes, only the reporting of the SAR.

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#8055 - 12/19/01 09:09 PM Re: SAR Reporting to Board
NotALawyer Offline
Gold Star
NotALawyer
Joined: Nov 2001
Posts: 455
We have not released any names to the borad either verbally or in writing. However, we have not had anything come up requiring filing on bank employees. The board has been more concerned with amounts, details of the situation, and what managment has done/is doing to help prevent similar events in the future.

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Robert Marx
Opinions stated are not necessarily that of my employer.


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#8056 - 12/19/01 10:01 PM Re: SAR Reporting to Board
La. Lady Offline
Diamond Poster
La. Lady
Joined: May 2001
Posts: 1,873
Thanks everyone....I haven't mentioned the name either, except for the Bank President.......I shutter to think....after all everyone knows the confidentiality that these Board Members have.
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#8057 - 06/06/03 07:52 PM Re: SAR Reporting to Board
drvmecrazy Offline
100 Club
Joined: Mar 2002
Posts: 232
I have notified the BOD of initial SAR filings. Am I also supposed to notify them of subsequent filings on the same individual?
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#8058 - 06/06/03 08:00 PM Re: SAR Reporting to Board
1111 Offline
Platinum Poster
1111
Joined: Jan 2003
Posts: 580
Yes, all SAR filings must be reported to the BOD.

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#8059 - 06/06/03 08:06 PM Re: SAR Reporting to Board
drvmecrazy Offline
100 Club
Joined: Mar 2002
Posts: 232
Thank you
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#8060 - 06/06/03 08:29 PM Re: SAR Reporting to Board
Anonymous
Unregistered

Do any of you report your SARs to your State regulators (i.e., send them a copy), in addition to Fincen?

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#8061 - 06/06/03 08:33 PM Re: SAR Reporting to Board
yy2say Offline
Gold Star
yy2say
Joined: Apr 2002
Posts: 279
PA
Quote:

Yes, all SAR filings must be reported to the BOD.


To the BOD or a committee of the BOD. We send all ours to the Audit Committee and have had no problems.
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