SAR Reporting at the Holding Company Level

Question:

Our organizational structure consists of a single bank charter that is whollyowned by a bank holding company. Can we meet the requirements for SAR reporting to the Board of Directors through a holding company Board Committee, or must the reporting occur to the Board/Committee of the subsidiary bank itself?

Answer:

Each regulatory agency has its own regulation requiring that SARs be reported to the board of directors. Generally, it would be critical to know who your primary federal regulatory agency is in order to look at the correct regulation.

In this case it doesn't make a difference none of their regulations directly answer your question. In a one bank holding company, your method would probably get the information to the right people, but anyone advising you that your method is O.K. would be guessing. This is not an area where guessing works. Check with your regulatory agency's regional office or legal department. If your contact says its O.K., see if she will write you a letter to that effect. At a minimum, if you are going to rely on telephone advice, write her a letter recapping your conversation.

First published on BankersOnline.com 7/1/02