90 Day SAR Review

In reviewing SARs after 90 Days to determine whether or not to re-file, what are most of you keeping as documentation that you performed the review and chose not to file another SAR to due changes in the account activity (or non-reoccurrences)?

Varies depending upon case but could include review narrative listing scope of review or actual copies of statements, screen prints, etc. Narrative should also include specific reason why the activity is no longer considered suspicious and what additional actions, if any, are planned.

I do a memo to file explaining why one wasn't done.

Due to the risk factors (previous sar), the review of this account should require enhanced scrutiny. Meaning, regulators would expect you to conduct an adequate 90 review and document your process as you would to any other high risk customer.

In our case, we have a word template that is utilize to document all inflow and outflow activities, communication with staff and/or customers (if any), etc... The more you document your conclusion not to file the less scrutinity you would face.

Keep in mind, that for consistency, this process should be addressed in your P&P.

We usually do a memo to the file stating the activity within the 90 day watch period which should (in theory) support our decision not to file.

I have a template that I use to document the scope, findings and recommendations for each review which I retain and present to the examiner when she asks for it. We also maintain a spreadsheet that follows each entity and subsequent review for a quick reference.

I have a spreadsheet/notebook that lists all of the SARs filed. I note if they are no longer open - the closed date, comments, last date reviewed, and date SAR filed. I have copies of transactions showing, for instance, no evidence of continuing activity for kiting or structuring. The FDIC appears to like it OK.

I use a tabbed Excel workbook for HRE tracking with a spreadsheet for each month that documents what was reviewed that month and the decision made. The top sheet is an overall tracking of HRE accounts showing when they were added to the HRE and when they were removed. Law enforcement contacts are listed on that sheet. When an account is removed from HRE tracking, the row from the last month it was reviewed is added to a spreadsheet of all accounts removed from HRE tracking. That Excel workbook rides tandem with the SAR filing log (also an Excel workbook) which is tabbed by year and by filed/not filed. All documentation is scanned into a sub-folder for each HRE entity based on when it was done and all SAR documentation is scanned into a sub-folder showing the date the SAR was filed. It works for us and for the regulators. If we make a decision not to file, we document it on the SAR log, but unless the account has been closed, we track it on the HRE log for at least 4 consecutive quarters.