Ongoing Reviews and SAR Follow-Up

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Question:

Should monitoring of an on-going situation for which a SAR was filed by a branch manager be done by that manager who actually sees the behavior or by the security department? Are there any restrictions regarding the employees who complete SARs from keeping a copy of what they wrote for purposes of updates, monitoring, or filing supplementals?

Answer:

Although it's likely that your security officer will have responsibility for ensuring that monitoring takes place and that follow-up SARs are filed as warranted, it makes good sense to involve the person or persons most likely to observe the customer's behavior. Take care, however, that the "in the trenches" observations aren't colored by excessive familiarity with the customer. You can consider the phrases "Can't see the forest for the trees," or "Too close to the situation," as suggestions.

As for allowing those involved in the filing of the SAR to have copies of what they wrote, I encourage it to assist in follow-up. However, anything that is retained needs to be copied in the master SAR file, and "local copies" need to be secure.

First published on BankersOnline.com 08/16/04