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#1474123 - 12/01/10 12:51 PM Re: BSA - dual control? J2C
Retired DQ 10K Club Joined: Dec 2002 Posts: 40,766 Turnpike Exit 10	Originally Posted By: jennyfromthebloc Originally Posted By: The Deek, CRCM We formed a SAR committee (Internal audit, compliance and BSA) to review all cases before filing or not filing. Minutes are recorded and reported to the BOD. Internal audit, really? Yes, the examiners are here and they like it, because he is totally independent (of dep/lend/ops). Besides, our full blown BSA Ind audit is done externally, so there is no conflict. _________________________ Get your facts first, then you can distort them as you please. - Mark Twain
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#1474272 - 12/01/10 03:49 PM Re: BSA - dual control? Retired DQ
J2C Diamond Poster Joined: May 2004 Posts: 1,475 Big Brother knows and that's a...	Originally Posted By: The Deek, CRCM Besides, our full blown BSA Ind audit is done externally, so there is no conflict. Well, that makes more sense then since the BSA audit is outsourced. Is there a reason that particular audit is outsourced? Just curious. _________________________ My opinion is mine only- not my employer's!
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#1474276 - 12/01/10 03:51 PM Re: BSA - dual control? J2C
Retired DQ 10K Club Joined: Dec 2002 Posts: 40,766 Turnpike Exit 10	Yeah, it is way more comprehensive, plus BSA reports to me. That and Fair Lending are the only ones I outsource. _________________________ Get your facts first, then you can distort them as you please. - Mark Twain
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#1476097 - 12/03/10 08:37 PM Re: BSA - dual control? Retired DQ
BowlingQueen Power Poster Joined: Mar 2007 Posts: 2,920 Wisconsin	At my "small" community bank (w/a total staff of about 100), the tellers complete the CTRs at the time of the transaction(s). Then they are sent in each day to our Administrative Assistant who enters them into our CTR system. Our BSA Administrator then edits the CTR info for accuracy before she e-files them. Our Compliance/BSA Officer doesn't even sniff the CTRs, but he does file all of our SARs. _________________________ Nothing changes, if nothing changes. (from a good friend of mine)
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#1477741 - 12/08/10 05:22 PM Re: BSA - dual control? BowlingQueen
rdelgado 100 Club Joined: Dec 2005 Posts: 116	Originally Posted By: BowlingQueen At my "small" community bank (w/a total staff of about 100), the tellers complete the CTRs at the time of the transaction(s). Then they are sent in each day to our Administrative Assistant who enters them into our CTR system. Our BSA Administrator then edits the CTR info for accuracy before she e-files them. Our Compliance/BSA Officer doesn't even sniff the CTRs, but he does file all of our SARs. We have exactly the same process. We are a larger community bank (up to 26 branches now). Different job titles, but the same steps. _________________________ In order to discover who you are, first learn who everybody else is. You're what's left. -A Fortune Cookie
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#1477762 - 12/08/10 05:38 PM Re: BSA - dual control? rdelgado
Elwood P. Dowd 10K Club Joined: Aug 2001 Posts: 21,939 Next to Harvey	Quote: Our BSA Administrator then edits the CTR info for accuracy before she e-files them. When your BSA Administrator changes the information on a CTR does he or she then list herself as the preparer in Box 47? A "no" answer suggests that the person listed as the preparer of the form is now responsible for something he or she did not even see. Some banks refer incorrect forms to the preparer for correction...makes them think about it a bit more the next time. _________________________ In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.
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#1478140 - 12/08/10 10:21 PM Re: BSA - dual control? Elwood P. Dowd
BowlingQueen Power Poster Joined: Mar 2007 Posts: 2,920 Wisconsin	The original preparer's name stays on the paper CTR, but the BSA Administrator's name actually goes with the e-filing. Trying to get 100% correct CTRs from all of our tellers would be an exercise in futility, if you know what I mean. We conduct training on an annual basis, plus they have templates for the customers that we repeatedly file on....and they STILL manage to find ways to botch them up. _________________________ Nothing changes, if nothing changes. (from a good friend of mine)
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