OCC head Thomas Curry gave a speech yesterday where he stated:
"Under the SAR rules, banks are encouraged to file copies of SARs with state and local law enforcement agencies where appropriate, including SARs that report alleged elder abuse."
http://www.occ.gov/news-issuances/speeches/2015/pub-speech-2015-45.pdf
really - are we encouraged to share the actual SARs with law enforcement officials?

National banks are encouraged, and in some cases, it's a little stronger than encouragement. See 12 CFR 21.11(e): Reports to state and local authorities. National banks are encouraged to file a copy of the SAR with state and local law enforcement agencies where appropriate.

See also 12 CFR 21.11(d), which reads, in relevant part: "In situations involving violations requiring immediate attention, such as when a reportable violation is ongoing, the financial institution shall immediately notify, by telephone, an appropriate law enforcement authority and the OCC in addition to filing a timely SAR."

State member banks follow similar language in the Fed's Regulation H at section 208.62 (paragraphs (d) and (e)). State non-member banks have similar language in the FDIC's regulations at 12 CFR 353.3(b)(2) and (c).

Consider whether they need the information or whether they need the SAR. I'll vote for the former.

that's my point - what good is giving the local guys the SAR - it is the facts contained in the SAR that need to be reported

and if the local guys had the SAR and divulged that the information was in a SAR, wouldn't you lose your safe harbor?

The "local guys" all have access to the SAR database if they want the actual document.

No, but that's a very common misconception and I've always wondered where it came from.

I think the takeaway from this discussion is that in certain cases it makes perfect sense to notify local law enforcement moments after having filed the SAR. That notification is probably most effective if it's all about the suspect activity and not about the fact that the SAR was filed, but you can legally provide a copy of the SAR if you wish to without endangering your safe harbor.

I would not want to be the bank that filed a SAR on an ongoing embezzlement and failed to notify local authorities based on the fact they have access to the SAR database, thus failing to timely stop the bleeding of some local business's or non-profit's assets.