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Suspicious Activity Report: Decision Making & Documentation
(Presented By: Ken Golliher)
You may know how to fill out the form, but do you have of a SAR filing structure that a third party reviewer can recognize and evaluate? If so, how well does that structure work? Can you show evidence of an objective, consistent process for making SAR decisions, one so effective that it allows you to explain why your institution did not file a SAR?  | WEBINAR TIME:
11:30AM - 1:30PM PT
12:30PM - 2:30PM MT
1:30PM - 3:30PM CT
2:30PM - 4:30PM ET |  |
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WHAT?
Effective suspicious activity reporting requires a dependable flow of information leading from a wide variety of sources; e.g. tellers, CSRs, legal process clerks, loan officers, operations personnel, etc. to an individual or group that makes SAR filing decisions. Those decision makers focus on 1) whether the activity is suspicious and 2) whether a Suspicious Activity Report (SAR) filing is required or advisable. That decision making process must be well documented, particularly in circumstances where a decision is made not to file a SAR.
In 1998 and again in 2004 the functional federal bank regulatory agencies sent Interagency Memoranda indicating all federally supervised financial institutions should establish internal processes for the filing of SARs. Many have neglected this responsibility.
WHY?
BSA/AML enforcement actions rarely cite individual instances of Suspicious Activity Report (SAR) filing failures. What they routinely criticize is the absence of a dependable SAR filing structure. It's a weakness that leads to systemic failures in recognizing and reporting suspicious activity and exposes the bank to civil money penalties for nonfiling. From an even more practical standpoint, the BSA/AML Examination Handbook clearly indicates that examiners are to respect a bank's individual decision not to file a SAR its decision is based on adherence to its SAR filing policies and procedures. Implicit in that statement is the fact that if the bank has no SAR filing policies and procedures; i.e. every SAR decision is a "one off" decision, then the direction that examiners must respect the bank's individual decisions does not apply. In that circumstance, if examiners do not agree with a bank's decision not to file a SAR, they are free to criticize it.
Banks must have a demonstrable SAR filing and decision making process and this program focuses on how to build and document just such a process.
PROGRAM CONTENT
The presentation focuses on:
Training personnel at all levels to recognize and report suspicious activity,
Processing internal reports; e.g. to whom should reports be sent and how much information should they obtain
How much time do we have to file a SAR and when does that time begin to run?
Should SAR filing decisions be made by an individual or a committee?
If we have a SAR filing committee, who should be on it?
What are the "filling triggers" for SARs?
Board reporting, when and how much should be reported?
Repetitive filings, should we file forever or simply close the account?
What standards could we use for unilaterally closing an account?
This program does not deal with how to complete the form. That issue is addressed in a November 12 webinar, "SAR Completion."
SAMPLE PROCEDURES
Program materials include a number of sample procedures. The samples are not "one size fits all" procedures s that financial institutions can adopt as their own. They are teaching tools that are intended to illustrate that, while some elements are common to all SAR decision making processes, each financial institution has to develop a process that fits its own structure and risk levels. (Attendees at Ken's webinars are always very complimentary of the sample documents and language he includes in his materials.)
WHAT DO YOU WANT TO HEAR ABOUT DURING THE PROGRAM?
There will be Q & A's during the program, but if you want to submit questions in advance or make certain your topic is addressed, send them to seminars@bankersonline.com Put "SAR Decision Making" in the message line.
WHO?
Expected attendees are officers and auditors employed by banks, thrifts and credit unions who are responsible for building or evaluating a SAR filing structure. SAR committee members will also find the presentation very helpful. The program focuses on the process leading up to a decision to file or not file a SAR, it does not address the completion of the form. Consider attending the companion program on SAR Completion on November 12.
About the Speaker:
Ken Golliher is a principal with Pegasus Educational Services, LLC, a training firm headquartered in Louisville, Kentucky. He is an experienced banker with a unique ability to reduce complex legal concepts to plain English. He has explained the "why" and "how" of regulations to thousands of financial institution personnel and examiners. Ken's banking career began in 1972 and includes serving as a teller, commercial operations manager and as trust department legal counsel in a state and a national bank. For ten years he headed the education division of a regional consulting firm for financial institutions. He has served on the faculty of the LSU Graduate School of Banking, the OTS' Level I Compliance School and the FDIC's Advanced Consumer Protection School for examiners. He has presented seminars in more than 25 states and has served as an instructor at compliance schools sponsored by the Illinois, Indiana, Georgia, Kansas, Kentucky, Nebraska, Pennsylvania and Texas bankers associations. He is one of the moderators for the Bank Secrecy Act forum at http://www.bankersonline.com/
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