I thought they OK'd the release of SARs through a grand jury subpoena?
This standard would permit, for
example, official disclosures responsive
to a grand jury subpoena; a request from
an appropriate Federal or State law
enforcement or regulatory agency; a
request from an appropriate
Congressional committee or
subcommittees; and prosecutorial
disclosures mandated by statute or the
Constitution, in connection with the
statement of a government witness to be
called at trial, the impeachment of a
government witness, or as material
exculpatory of a criminal defendant.
http://www.gpo.gov/fdsys/pkg/FR-2010-12-03/pdf/2010-29869.pdf