LAS VEGAS — NCUA's new rule on notifying credit union boards of suspicious activity reports can be handled without compromising confidentiality, according to a Washington attorney specializing in SAR regulations.
Satish M. Kini, a partner in Goodwin Proctor, LLP, said a monthly SARS recap providing numbers of filings, their makeup and comparisons with past months would suffice.
Only in cases where a CU employee is involved would there be the need to disclose to the full board the details of a SAR report, said Kini addressing attendees. The new SAR regulation became effective Nov. 27.
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During a question and answer portion, some members of the audience, made up of CEOs, audit and compliance staffers, expressed confusion on exactly what the breakdown would be on SARs reporting. Up to now, only banks had to notify boards of SARs filings, but CUs were not so required, Zini said.
Under the latest rules, CU staffers might still report 20 filings during the month broken down, for example, by category whether it be transfers, cash, etc. But further details would not be divulged, he cautioned.
Essentially agreeing with Zini was NCUA Board Member Gigi Hyland, also a speaker, who during a Q&A following her talk, said directors would need to know month-to-month SARs or CTR summary comparisons as a way of determining pattern changes requiring possible remedial action. –[email protected]
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