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#909334 - 02/22/08 10:10 PM Timely SAR Reporting to the Board
80's Lady Offline
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Joined: Apr 2007
Posts: 295
I have searched for clarity on this question with no luck, so thought I would ask for opinions. Currently I report SARS to the Board at the "next regularly scheduled monthly meeting" - for example if I filed a SAR today and the meeting was Monday I would include the SAR I filed today in a report to be distributed to the Board at Monday's meeting.

In the interest of efficiency, I would like to start reporting SARS filed on a "monthly" basis, i.e. all SARS filed in the month of February would be reported at the March Board meeting, with my cutoff being SARS filed through February 29th. This would give the Board more time to review and my report would be able to be included in the rest of their reports which they receive a few days prior to the meeting.

Any feedback on how you all are doing this and if you have received any critisism from your auditors or examiners?
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#909347 - 02/22/08 10:23 PM Re: Timely SAR Reporting to the Board 80's Lady
rlcarey Offline
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Galveston, TX
IMHO - that would be timely and meet the requirements. You don;t send them the actually SARs do you? They would become part of the board of director's meeting documentation and possible lead to being discoverable through subpoena - or at least there would be a fight.
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#909364 - 02/22/08 10:40 PM Re: Timely SAR Reporting to the Board rlcarey
80's Lady Offline
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Thanks for the input rlc. No we don't provide the actual SAR copies. We use a numbering system with a brief synopsis, never any names or account numbers.
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#909565 - 02/25/08 12:13 PM Re: Timely SAR Reporting to the Board 80's Lady
Retired DQ Offline
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Turnpike Exit 10
We do report on a monthly basis, the examiners have been fine with that. We include the same info as you, too.
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#909805 - 02/25/08 05:42 PM Re: Timely SAR Reporting to the Board Retired DQ
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
A while ago I followed the same process as you do now and I found it to be difficult since I would always need to know when I drafted the report (always at least 1 week in advance of BOD meeting)so I would know which SARs to include in the next month's report. I changed to the 'monthly' process and, aside from the fact that it is clean and easy, it has never been criticized.

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#909889 - 02/25/08 06:38 PM Re: Timely SAR Reporting to the Board devsfan
What?? Offline
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I file my report to the board on a quarterly basis. for example, my board meeting held in January would include the previous quarter report relating to SAR's CTR's etc.. I have never had a problem with my examiners.

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#909901 - 02/25/08 06:56 PM Re: Timely SAR Reporting to the Board What??
Skittles Offline
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TN
I file mine quarterly to the Audit Committee. We just had an exam, and although questioned, this ended up passing the test.
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#914736 - 03/04/08 07:07 PM Re: Timely SAR Reporting to the Board Skittles
ksm Offline
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ksm
Joined: May 2003
Posts: 302
Midwest
I have always prepared a summary board report of SARs for the Board Audit Committee which meets every other month. We have done this for many years and have not been critized. The examiner who is here now says the board report needs to be done monthly. We have a monthly Board meeting. I pulled out the exam manual and said I do not see any reference for needing to report to the Board in 30 days. The FDIC examiner said this is what they look for. Has anyone else been critized?

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#914746 - 03/04/08 07:18 PM Re: Timely SAR Reporting to the Board ksm
Skittles Offline
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TN
The FDIC just completed their BSA Exam of my institution and wanted to cite us for this also; however our Internal Auditor talked to them and informed them that this was how it was handled at her previous institution (and mine in Southern Indiana) and it had never been an issue. They backed off of the exception.

Good luck.
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#914768 - 03/04/08 07:43 PM Re: Timely SAR Reporting to the Board Skittles
John Burnett Offline
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John Burnett
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Cape Cod
Write it up in your BSA/AML policies and/or procedures. If the board wants the SAR report to go to the bi-monthly audit committee meeting, the board should indicate so in its minutes. If you can demonstrate to the examiner that (1) the board wants it that way, and (2) the board is sufficiently aware of SAR filings and the filing process to be able to provide adequate oversight, the examiner should be satisfied.

Oh, make sure your policy indicates that the full board will be notified at its own next monthly meeting (or sooner) in the event of a SAR filing on an insider (except that any board member SAR suspect will not be notified).
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#914771 - 03/04/08 07:45 PM Re: Timely SAR Reporting to the Board ksm
MidMOAuditor Offline
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Joined: Aug 2007
Posts: 105
Missouri
There is no mandating timeframe for SAR reporting. It's a risk based decision on the part of each financial institution. A larger institution who files multiple SARs each week would probably want to do a monthly report but a smaller community bank who might file one a month could choose quarterly reporting. The only thing that should be of issue is if you are doing something other that what your policy reflects and then you would have a policy violation.

As far as I know, there are only four monthly reports that are required to be given to the board.

all approvals and extensions of credit
past due report - specifically 90 days or more
aggregate indeptedness report
and debt to officers and employees
Last edited by MidMOAuditor; 03/04/08 07:47 PM.
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#915039 - 03/04/08 10:47 PM Re: Timely SAR Reporting to the Board MidMOAuditor
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
FWIW - I concur. A suggestion by the examiners for monthly reporting one thing. If they are going to cite it in the report, I would be squawking to high heaven.
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#915519 - 03/05/08 06:30 PM Re: Timely SAR Reporting to the Board John Burnett
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the beautiful state of ME
Quarterly audit committee meetings here, our regulator is the OCC and we have never been questioned - I just state the number of SARs filed and why (structuring, check fraud, etc).
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