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#909798 - 02/25/08 05:39 PM Question -Imaging of Bank Secrecy Documentation
CantBeShocked Offline
Gold Star
Joined: Apr 2006
Posts: 260
MS
How many of you image your BSA documentation ? Do any of you dare image your SARs ? I am receiving pressure from higher ups to do so and am tugging my end of the rope hard to the negative. I have folders for SARs filed, MSB documentation, some reviews done upon which NO SAR was filed, and NRAs. It is much easier for me to pull a folder with all docuemntation for quick review versus pulling it up electronically.

I have CDD reviews / EDD reviews in my NRA folders too that I do not want imaged.

Please give your opinion & if any of you have had "official" guidance from a regulator, I would appreciate that too. Basically, I need some ammunition to help because despite the power I am supposed to have as the BSA Officer, I do not have it or get it here

Thanks.
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#909859 - 02/25/08 06:15 PM Re: Question -Imaging of Bank Secrecy Documentation CantBeShocked
Islandgirl Offline
100 Club
Joined: Nov 2005
Posts: 173
Louisiana
At my bank, we image CIP worksheets. I keep files the same as you on SARs filed & suspicious but not filed after further review. CIP is all that is imaged as far as BSA. I have not had any negative responses from examiners. I hope this helps you.

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#909874 - 02/25/08 06:23 PM Re: Question -Imaging of Bank Secrecy Documentation CantBeShocked
ahou Offline
Power Poster
ahou
Joined: Aug 2002
Posts: 3,094
We are being pushed into paperless also. I don't think examiners will care if your record retention is electronic.
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#909881 - 02/25/08 06:29 PM Re: Question -Imaging of Bank Secrecy Documentation ahou
CantBeShocked Offline
Gold Star
Joined: Apr 2006
Posts: 260
MS
Are none of them worried about a Security lax or some new person in Imaging publishing them into the wrong folder in the system and then them becoming public ? It's a really big concern for me given that my neck is the one on the line if it happens because I'm ultimately responsible :-)
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#910155 - 02/25/08 10:45 PM Re: Question -Imaging of Bank Secrecy Documentation CantBeShocked
Little Miss BSA Offline
Diamond Poster
Little Miss BSA
Joined: May 2007
Posts: 1,185
Miami
At my previous institution we imaged almost everything BSA related, including e-mails, memos, info requests, etc. sent to account offciers....but we NEVER, noe would I have allowed them to image the SARs. I too had a SAR file for each SAR completed that contained all of the documentation pertinent to that specific SAR. In addition I also had an electronic version saved on my own protected drive, but that was only because we completed an electronic version of the form.

Hope this helps...
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#911158 - 02/27/08 03:32 PM Re: Question -Imaging of Bank Secrecy Documentation Little Miss BSA
CantBeShocked Offline
Gold Star
Joined: Apr 2006
Posts: 260
MS
Moving this one up in hopes of more replies. How many of you image BSA documentation ?

Thanks.
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#911373 - 02/27/08 05:39 PM Re: Question -Imaging of Bank Secrecy Documentation CantBeShocked
Compliance Mom Offline
Junior Member
Joined: Apr 2003
Posts: 45
Tennessee
We image CIP only. Our regulators, FDIC, love to have a hard file in front of them with all backup docs. We do have an electronic copy of SARs, as they are efiled, but these are in a restricted directory with limited access to BSA officer and specialist.

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