VIDEO: SAR for Teller Error
In this Compliance Clip (video), Adam answers a question about whether a SAR is required when a customer won’t provide needed BSA information - which is missing due to a teller error.
Video Transcript
The following is a transcript of this video.
In this Compliance Clip, we’re going to talk about filing SAR for a teller error. Specifically, this week, I saw a question come in. It asked this: We filed a CTR for a non-customer who provided us with their social security number, but the teller forgot to write it down and didn't make a copy. Then the teller realized it did require a CTR and so the social security number was missing. Now the non-customer would not return our calls when we're calling them asking for the number. Since they’re avoiding our calls and not providing the social security number, should we file a SAR for this activity?
This is a question I've seen asked over the years. Really what this comes down to is your financial institution, in this case, if this was you, your financial institution was the one that made the error. It wasn’t the customer. They complied with BSA rules, they provided all the information that was needed. They provided their driver's license, their social security number and everything but you forgot to write it down. At the end of the day, they felt like they provided it so they’re not giving you a call back.
I don’t believe a suspicious activity report should be filed in this case because in this specific instance what you had was a teller error. What I've learned is that consumers will do most things that need to be done before they get the money, but once they get their money, forget it. The same goes for opening new accounts. If you don't ask for a driver's license but you open their account and make an exception, they're never going to bring it in. That's just how it works. In this case, I would not view this as suspicious activity in and of itself because of this teller error.
That's all I have for you today in this Compliance Clip.