As a financial institution, SAR reporting is a critical function that can result in violations being cited in an exam report.  Because of this, it is extremely important to fully understand the reporting rules, of which there are quite a few.  One of those rules relates to the timeframe for SAR reporting - i.e., how long a financial institution has to file SAR.

Several years ago, I had just arrived on-site for a bank visit when the BSA Officer quickly pulled me into her office and shut the door.  She had a dilemma: she had filed a SAR on a director and was faced with the challenge of how she was going to report that SAR to her board.  Her challenge was that the board had a practice of viewing a copy of the entire completed SAR and if she continued on with this practice, should be be disclosing to the director that the bank had filed a SAR on him.  This, of course, would be problematic for a number of reasons: unlawful disclosure and a very uncomfortable boardroom are two of them.  Fortunately for this BSA Officer, I had a simple solution for her.