SAR Question about a Closed Account

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Question:

We have a customer who has been kiting very obviously for the past two years. I have filed a SAR on them every quarter for the past two years. I have fianlly convinced management to close his account. The last SAR was filed in July, and the account was closed in October. There doesn't appear to be any kiting activity since my previous filing, but should I still file the SAR because we finally closed the account, and a SAR has been filed every quarter for the past two years?

Answer:

No. Filing the SAR isn't needed. Instead, document your file on this customer to show that there was no additional kiting since the last SAR filing and that the account is now closed. That becomes your justification for a non-filing decision.

First published on BankersOnline.com 11/23/09