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#951008 - 04/28/08 09:35 PM CTR and SAR?
CSB98 Offline
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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?

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#951014 - 04/28/08 09:42 PM Re: CTR and SAR? CSB98
JacF Offline

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I have never heard that one before. Did either you or the BSA Officer follow up with the examiner about this suggestion?

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#951027 - 04/28/08 09:52 PM Re: CTR and SAR? CSB98
KC Danimal Offline
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I will call B.S. on that suggestion.
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#951031 - 04/28/08 09:54 PM Re: CTR and SAR? KC Danimal
BrendaC Offline
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I believe there is a miscommunication somewhere. I would circle back with the examiner and discuss further.
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#951045 - 04/28/08 10:08 PM Re: CTR and SAR? BrendaC
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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!
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#951181 - 04/29/08 01:20 PM Re: CTR and SAR? JacF
CSB98 Offline
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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.

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#951266 - 04/29/08 02:27 PM Re: CTR and SAR? CSB98
BrendaC Offline
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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.
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#951277 - 04/29/08 02:34 PM Re: CTR and SAR? CSB98
WreckEmTech Offline
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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.

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

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Did this comment make the examiner's written report?

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#951457 - 04/29/08 04:53 PM Re: CTR and SAR? CSB98
Compliance Mom Offline
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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.
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#951508 - 04/29/08 05:39 PM Re: CTR and SAR? Compliance Mom
Dallas Fan Offline
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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.

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#951514 - 04/29/08 05:45 PM Re: CTR and SAR? Dallas Fan
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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.

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#951522 - 04/29/08 05:52 PM Re: CTR and SAR? WreckEmTech
CSB98 Offline
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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.

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#953612 - 05/02/08 03:31 PM Re: CTR and SAR? CSB98
CantBeShocked Offline
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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.
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