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Suspicious Activity Report: Form Completion
(Presented By: Ken Golliher)
Proper SAR completion requires thorough, focused training as well as an understanding of how the form is used by law enforcement personnel.
WHAT?
This webinar focuses on how depositary institutions are to complete the Suspicious Activity Report (SAR), Form TD F 90-22.47. SAR filing is required in regulations promulgated by the federal functional bank regulatory agencies as well as regulations interpreting the Bank Secrecy Act (BSA) issued by the Financial Crimes Enforcement Network.  | 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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WHY?
About 720,000 SARs were filed in 2009. Regulators are increasingly focusing on "SAR quality" in their on-site reviews.
SAR completion is the end result of a time consuming and expensive process of monitoring and evaluating customer activity and should reflect the depositary institution's best efforts. This program describes how to properly complete the form and make it an effective vehicle for delivering information to law enforcement. It places a significant amount of emphasis on writing the SAR narrative and clearly describing the supporting documentation.
PROGRAM CONTENT
- How to get detailed SAR filing information for your state
- Finding the rest of the instructions for the current SAR
- Filing triggers from FinCEN regulations
- Filing triggers from regulatory agency regulations
- Using case numbers
- Identifying suspects vs. victims
- Detailed descriptions for each of the 20 reasons for SAR filing
- When to check multiple reasons for SAR filing
- When to use "Other" as a reason for SAR filing
- SAR narrative "key terms": what do they mean? When do we use them?
- Proper SAR completion for "ongoing" suspicious activity
- Organizing the SAR narrative in chronological order
- Addressing "Who, what, when, where, why & how" in the narrative
- Facilitating law enforcement "data mining" operations in the narrative
- Properly describing supporting documentation
This program does not deal with how to develop a SAR filing process. That issue is addressed in separate CD-ROM, "SAR Decision Making and Documentation."
WHO?
Expected attendees are officers and auditors employed by depository institutions who are responsible for completing or reviewing SARs. It does not address SAR filing responsibilities for other types of filers.
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, Iowa, Georgia, Kansas, Kentucky, Nebraska, Oklahoma, Pennsylvania and Texas bankers associations. He is a member of the Society for Applied Learning Technology. He is also a moderator of the General, BSA, and Operations forums at Bankersonline.
More information...
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888-229-8872