Every year we submit a report to the Board to evidence BSA compliance. The report includes the following: 1) Number of CTRS filed, 2) Number of exemptions granted, 3) Number of active exemptions granted, 4) BSA training, 5) Exemption status review dates, 6) Other.

Does anyone else do this? I cannot find where this is required by the regulation. I think this is something we must have decided to do, but noone knows why. I am considering the recommendation that this report not be created any more. It takes a lot of time and it is something that the examiners could come back on at a later date. Any thoughts?

Documenting your BSA compliance activities is an excellent idea, whether it takes place as a report to your board or one to senior management makes no difference. It can even be just a note to your files to assist you in assessing the quality and quantity of what you're doing. It also can be a useful tool for audits and exams.

Having your board apprised of your BSA activities, however, is always a great idea. They are charged with knowing what's going on in this area, and having your report delivered to them -- even if it's only a written report that gets filed with the record -- helps document their involvement.

And it's never a bad idea for your activities on behalf of the bank's BSA effort to be documented for the board. It shows how valuable you are!

I agree with John Mack. My original thought was that we don't currently do it but I think it sounds like a good idea. It could only help you during an exam. BTW, love the new avatar, it's adorable!

Our Supervisory Committe has asked for a monthly summary -- the Board doesn't really want to know.

Our executive committee charged with security matters receives such a report, but we would not burden our board package with this. They approve policy and charge our management to comply. Our internal auditors, external auditors and examiners all monitor BSA activity and report to the board their findings. That is enough for us. Our monthly board packages are huge as it is. It is a matter of personal choice at this point, so we have chosen to view this info as a management report. Whew !, let me get down off this soapbox now.

Don do you feel better now? If you want the truth, I dare say that the Directors even look at this report. It is a simple one page report put in the board packets once a year. Our bank is not large enough to warrant any type of oversight committees to report ongoing compliance efforts to, so the examiners like to see that we are keeping the Exec. Mgmt and directors up on our compliance activity.

I would just love to be a fly on the wall in these board meetings to know exactly what they do/do not discuss.

Oh, Don...you can get up on your soapbox anytime you want to! You always have good input that is appreciated.

We do similar reporting to our Board on a quarterly basis. In addition to the information originally addressed we also cover number of due diligence reviews, suspicious activity investigations, SARs filed, FinCEN & OFAC program matches, misc BSA/AML program activities and impact of any new regulations.

It's critical that there be a lot of board reporting on BSA, and the entire Anti-Money Laundering program. Examiners will find deficiencies if the BSA Officer has not informed the Directors on the overall report card and how well the bank is implementing/managing each area's BSA Compliance. An overall risk assessment and assessment by product line/ business line, is also important and shows that you (as BSA Officer) have looked at everything comprehensively.

I'm wondering if anyone is willing to post a sample of the report that they send to their board. I have to do one and am at a loss on how detailed to make it. My Board is still learning all this stuff so they are interested. Remember plagiary is the sincerest form of flattery. Thanks in advance.

I suggest a simple report hte number of items filed and also a breakdown of category. If you have a small number of branches you might also want to give breakdown by branch. No customer detail, unless they request it.

Your risk assessment, not a "requirement" when this thread was started, is going to include a synopsis of your CTR and SAR filing as well as an analysis of any notable trends. That should limit, if not eliminate, the need for any separate report.