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Guidance for Filing SAR on an Employee

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I recently saw a response in a BOL Thread that "suggested" that when a bank is required to file a SAR on an employee (or insider) that the bank should also notify its primary banking regulator. I can find no other guidance on this matter and want to know when, or if, this is a requirement to notify our regulator when we file an employee/insider SAR.

It is not required that a bank notify its primary regulator when an SAR is filed on an employee, but can be viewed as a courtesy. Some regulators have specifically asked for a "heads up" on employee or other potential high profile SARs. It can take a few weeks before knowledge of SARs filed makes its way to your specific regulators, hence the request for notice. This is similar to notifying your regulator if you find a legal lending limit violation, information security breach (although this is required), etc. They don't want unpleasant surprises. This would be especially important in a situation where an employee might be arrested and the story gets in to the newspaper. Regulators don't want to find out these things by a call from a reporter.

First published on 1/22/07

First published on 01/22/2007

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