CTR and SAR?

Posted By: CSB98

CTR and SAR? - 04/28/08 09:35 PM

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?
Posted By: JacF

Re: CTR and SAR? - 04/28/08 09:42 PM

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

Re: CTR and SAR? - 04/28/08 09:52 PM

I will call B.S. on that suggestion.
Posted By: BrendaC

Re: CTR and SAR? - 04/28/08 09:54 PM

I believe there is a miscommunication somewhere. I would circle back with the examiner and discuss further.
Posted By: Darkhorse

Re: CTR and SAR? - 04/28/08 10:08 PM

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!
Posted By: CSB98

Re: CTR and SAR? - 04/29/08 01:20 PM

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.
Posted By: BrendaC

Re: CTR and SAR? - 04/29/08 02:27 PM

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.
Posted By: WreckEmTech

Re: CTR and SAR? - 04/29/08 02:34 PM

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.
Posted By: JacF

Re: CTR and SAR? - 04/29/08 02:45 PM

Did this comment make the examiner's written report?
Posted By: Compliance Mom

Re: CTR and SAR? - 04/29/08 04:53 PM

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.
Posted By: Dallas Fan

Re: CTR and SAR? - 04/29/08 05:39 PM

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.
Posted By: NewTooBSA

Re: CTR and SAR? - 04/29/08 05:45 PM

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.
Posted By: CSB98

Re: CTR and SAR? - 04/29/08 05:52 PM

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.
Posted By: CantBeShocked

Re: CTR and SAR? - 05/02/08 03:31 PM

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.