During a recent internal audit - I was told that a SAR (original file date 2007 for structuring) and I have been filing a SAR every 90 days since, also the IRS has been requesting supporting documentation for this SAR - The auditor said this was too long to be filing and I need to either close the accounts or make a decision not to file - yet the structuring has not stopped. Any thoughts/suggestions???

Tell the auditor to stick with auditing and the bank will stick with making the business decisions.

You policies should address the process in which management or a committee reviews customers that are subject to repeat filings for the proper course of action by the bank. The bank's decision is final.

Thanks and our policy does address the process.

Thanks again!