I am the BSA officer for the bank, but work for the holding company. When I file a SAR for the bank, does that need to go to the bank Board and the Holding Co Board, or just the bank board?

I would submit info to Bank board. I would also make sure that a SAR sharing agreement is in place pursuant to recent SAR sharing guidance issued by FinCEN. I would have that agreement presented to both Boards.

Thanks BrendaC, but can you point me in the direction I can find that recent SAR sharing guidance by FinCEN.

The Guidance was issued on an interagency basis. As already noted, you are only required to report to the board of the bank. The guidance only applies if you plan to share the information at a higher level within your corporate structure.

FinCEN's Web Site under "What's New".

Thanks to you both for the information.

Shop,

We recently completed our state examination and one of the recommendations was that our SAR process be outlined in our BSA policy. I included the individual (BSA Officer) responsible for filing the each SAR, all members of our SAR committee, where the SAR's are filed(FinCEN and State banking department). This also included anyone who would be notified which for us is our Board of Directors. What I am trying to say is, I would put in your policy who will be notified and then follow your policy. I am not sure if this is a requirement or but since our state examiners recommended it, I went ahead and included it in our policy.

We were also strongly "encouraged" to expand our SAR procedures in our BSA Manual to include reporting a SAR on a Board member, account closure policy, what to do with investigative info if SAR is not filed, document sources used to identify suspicious activity (reports reviewed when/by whom; criminal subpoenas, etc.).

Thanks so much for the info.......but, if I am employed by the holding company who owns the bank and I am named as the BSA officer for the bank and therefore responsible for filing the SAR's, wouldn't I need to have in place the agreement the agencies are talking about? If so, does anyone have any suggestions on a format for this agreement?