Skip to content
BOL Conferences
Thread Options
#951008 - 04/28/08 09:35 PM CTR and SAR?
CSB98 Offline
Diamond Poster
Joined: Dec 2003
Posts: 1,337
Wisconsin
We just completed a Safety and Soundness exam with the FDIC and one if the examiners "recommended" that each time we file a CTR we should be filing a SAR as well. I think that's hogwash and have told the BSA Officer that I don't agree with this and that she should file SARs only when necessary. Is this something that's becoming more common?

Return to Top
BSA/AML/CIP/OFAC Forum
#951014 - 04/28/08 09:42 PM Re: CTR and SAR? CSB98
JacF Offline

Power Poster
Joined: Nov 2001
Posts: 6,719
PA
I have never heard that one before. Did either you or the BSA Officer follow up with the examiner about this suggestion?

Return to Top
#951027 - 04/28/08 09:52 PM Re: CTR and SAR? CSB98
KC Danimal Offline
Platinum Poster
KC Danimal
Joined: Sep 2005
Posts: 923
Kansas City
I will call B.S. on that suggestion.
_________________________
Opinions are mine and not necessarily those of my employer

Return to Top
#951031 - 04/28/08 09:54 PM Re: CTR and SAR? KC Danimal
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
I believe there is a miscommunication somewhere. I would circle back with the examiner and discuss further.
_________________________
Life without Jesus is like an unsharpened pencil - it has no point.

Return to Top
#951045 - 04/28/08 10:08 PM Re: CTR and SAR? BrendaC
Darkhorse Offline
Platinum Poster
Darkhorse
Joined: Nov 2004
Posts: 501
out of my mind
Originally Posted By: BrendaC
I believe there is a miscommunication somewhere. I would circle back with the examiner and discuss further.


Ditto. I just finished my FDIC BSA portion on Friday and the examiner didn't say anything even remotely similar to that!
_________________________
I'm gonna show him what a lil girl's made of: Gunpowder & Lead!

proud 2 b BOLWYWTCCUT

Return to Top
#951181 - 04/29/08 01:20 PM Re: CTR and SAR? JacF
CSB98 Offline
Diamond Poster
Joined: Dec 2003
Posts: 1,337
Wisconsin
I was on maternity leave while the exam was going on so found out about it after I got back. Believe me, if I would have been here something would have been said about it.

Return to Top
#951266 - 04/29/08 02:27 PM Re: CTR and SAR? CSB98
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
Someone has to discuss the matter further; whether it is the BSA officer or bank president it can't be left with that understanding of the SAR requirements. It is wrong and must be clarified.
_________________________
Life without Jesus is like an unsharpened pencil - it has no point.

Return to Top
#951277 - 04/29/08 02:34 PM Re: CTR and SAR? CSB98
WreckEmTech Offline
100 Club
Joined: Feb 2008
Posts: 154
Texas
Sounds crazy to me...are you guys filing SARs at all or at least keeping a record of SARs not filed?
If you aren't, I can see them suggesting that you might use the CTR triggering transactions as a starting point to uncover potential suspicious activity.
Otherwise, I'm guessing they couldn't find anything else wrong with your institution and had to find something to pick on you about.
I suggest getting your hands on a copy of the review so that you can see for yourself. If you still can't get clarification, call your head examiner.

Return to Top
#951301 - 04/29/08 02:45 PM Re: CTR and SAR? CSB98
JacF Offline

Power Poster
Joined: Nov 2001
Posts: 6,719
PA
Did this comment make the examiner's written report?

Return to Top
#951457 - 04/29/08 04:53 PM Re: CTR and SAR? CSB98
Compliance Mom Offline
Junior Member
Joined: Apr 2003
Posts: 45
Tennessee
I recently posted regarding something similar that came up in our Feb. exam. Our FDIC examiner, considered to be the BSA expert for our state, has told us anytime an individual conducts a large cash transaction, large enough for CTR filing, we should file a SAR on it unless we can come up with a good explanation for their activity. They are emphasizing "unusual" should be viewed as suspicious. Based on this mandate, we have already filed hundreds of SARS (literally) this year. Enough to warrant a full time SAR filer for our less than $5b institution.
_________________________
In Tennessee...
Possums sleep in the middle of the road with their feet in the air.

Return to Top
#951508 - 04/29/08 05:39 PM Re: CTR and SAR? Compliance Mom
Dallas Fan Offline
100 Club
Joined: Feb 2008
Posts: 219
RIC
That's crazy. This is not the intended purpose of a SAR. If all bank's did this FinCEn would be completely overwhelmed and they would undoubtedly miss SARs that are legit. I would appeal that request/demand in writing and fight it. It is overly and unduly burdensome.

Return to Top
#951514 - 04/29/08 05:45 PM Re: CTR and SAR? Dallas Fan
NewTooBSA Offline
Platinum Poster
Joined: Nov 2005
Posts: 568
Texas
Wow! And I thought my OCC examiner was over the line. We file 100+ CTRs almost daily and I can guarantee we do not file SARs on these customers.
I believe like the rest who have responded that the examiner has gone over the line. I would request they provide me examples of SARs that should have been filed that were not that involved cash where a CTR had been completed.

Return to Top
#951522 - 04/29/08 05:52 PM Re: CTR and SAR? WreckEmTech
CSB98 Offline
Diamond Poster
Joined: Dec 2003
Posts: 1,337
Wisconsin
Originally Posted By: WreckEmTech
Sounds crazy to me...are you guys filing SARs at all or at least keeping a record of SARs not filed?


We are filing SARs when warranted. We are a small community bank so the majority of CTRs filed are for people that have been long-time customers. Granted, you never know when something shady could be going on, but if the dollar amount makes sense given the kind of work the customer does, then we're not going to file a SAR.

Return to Top
#953612 - 05/02/08 03:31 PM Re: CTR and SAR? CSB98
CantBeShocked Offline
Gold Star
Joined: Apr 2006
Posts: 260
MS
I'm just dittoing what everyone else has said - you would never automatically do that and yes, it is hogwash !

It sounds like you got an examiner who either (a) didn't know what he or she was talking about; or (b) did not communicate what he or she fully meant. If something were over $10,000 AND suspicious, yes, you would file both. But never would you just automatically file a SAR.
_________________________
]

Return to Top

Moderator:  Andy_Z