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Compare % of SAR Filings With Other Banks?

During my most recent BSA/AML report to the board, there was discussion regarding the number of cases/investigations we conduct versus the number of those that actually result in a SAR filing. The board asked if I could compare our percentage of filings with other banks. I'm not certain that there is a good way to do this comparison due to the many variables in each bank and how they address those variables. Do you have any advice how to properly address the question?

Answer by John Burnett: Inasmuch as divulging the filing of a SAR or information from which such a filing can be inferred is prohibited, I don't think you'll have a way to obtain any sort of statistics to compare your bank's filing activity to. There are some filing statistics by geographic location, but nothing like the HMDA stats that break things down to the reporter level.


Answer by Kathleen Blanchard: A bank could ask other peer banks for some statistics but it would have to incorporate types of customers, types of products and accounts etc to make such a comparison meaningful. A discussion with banks using the same AML software regarding number of alerts vs number of alerts resulting in SARs could also be attempted but again it is difficult to compare apples to apples and also difficult to engage in a meaningful conversation on a confidential topic.


Answer by Ken Golliher: From you to them: SAR filings are confidential and other banks are not going to share this type of information with me.

From me to you: This information would mean nothing. You acknowledged and Kaybee illustrated the reasons why bank to bank comparisons would be meaningless. I would suggest that a year-to-year comparison of investigations vs. filings in your bank would be of limited value, but it might help to keep them entertained and would allow you a semi-serious response to their request. Maybe you could offer to do that instead.

It's been a career-long fascination for me that boards are so easily distracted from the substantive issues they are supposed to consider.

First published on 4/15/13

First published on 04/15/2013

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