Question -Imaging of Bank Secrecy Documentation

How many of you image your BSA documentation ? Do any of you dare image your SARs ? I am receiving pressure from higher ups to do so and am tugging my end of the rope hard to the negative. I have folders for SARs filed, MSB documentation, some reviews done upon which NO SAR was filed, and NRAs. It is much easier for me to pull a folder with all docuemntation for quick review versus pulling it up electronically.

I have CDD reviews / EDD reviews in my NRA folders too that I do not want imaged.

Please give your opinion & if any of you have had "official" guidance from a regulator, I would appreciate that too. Basically, I need some ammunition to help because despite the power I am supposed to have as the BSA Officer, I do not have it or get it here

Thanks.

At my bank, we image CIP worksheets. I keep files the same as you on SARs filed & suspicious but not filed after further review. CIP is all that is imaged as far as BSA. I have not had any negative responses from examiners. I hope this helps you.

We are being pushed into paperless also. I don't think examiners will care if your record retention is electronic.

Are none of them worried about a Security lax or some new person in Imaging publishing them into the wrong folder in the system and then them becoming public ? It's a really big concern for me given that my neck is the one on the line if it happens because I'm ultimately responsible :-)

At my previous institution we imaged almost everything BSA related, including e-mails, memos, info requests, etc. sent to account offciers....but we NEVER, noe would I have allowed them to image the SARs. I too had a SAR file for each SAR completed that contained all of the documentation pertinent to that specific SAR. In addition I also had an electronic version saved on my own protected drive, but that was only because we completed an electronic version of the form.

Hope this helps...

Moving this one up in hopes of more replies. How many of you image BSA documentation ?

Thanks.

We image CIP only. Our regulators, FDIC, love to have a hard file in front of them with all backup docs. We do have an electronic copy of SARs, as they are efiled, but these are in a restricted directory with limited access to BSA officer and specialist.