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I Love SARs (Part 2 in a three part series)

August 19, 2009 by David Hood
2 comment(s)

In my last post I professed my love for SARs and it seems I'm not alone. The Economist also ran a story on SAR reporting, subtitled The Rise of Financial Crime in America. While I admit their graphics are far superior, there is a sub-story hidden behind the total # of SARs filed. As I promised in my earlier post, let's pull back the curtain on which institutions are filing the SARs and how that has changed over time.

So who is filing all these SARs? 

For 2008, the Comptroller of the Currency accounted for filing 47% of all SARs. After that however, the breakdown is pretty well spread out over the FDIC, OTS, NCUA and the Fed. While interesting, this doesn't exactly provide any startling revelations. What is more interesting is looking at the growth rate of SARs filed by institutions governed by each of these bodies. Since 2004, the fastest growth rates of SAR filing has been in OTS and NCUA governed institutions. What's more, the rates of SAR filing increases have remained high since 1997. Additionally, there are some institutions that appear to see their SAR filing slow down (It's all relative since all exhibit annual growth rates over 10%!). The most pronounced slowdowns are in the FED and FDIC that have seen growth rates fall from above 20% using 2000 as a baseline to closer to 10% using 2004 as a baseline.

That's all for this article. In my next post I'll dig one level deeper to reveal which specific types of SARs are being filed.


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Recent Comments:

Nittany
August 20, 2009 - 8:15 AM
"It is not surprising to me, to see the SAR %'s change as reflected. As mid tier and large banks continue to spend money on robust front end prevention systems and tools, it is inevitable the thieves that use the banking arena as their playground will migrate to the banks that offer the path of least resistance to engage in their financial thievery. You talk with any analyst or investigator and they will tell you one goal is to get the crook to bank at their competitor down the street. In my opinion the crooks have a stronger communication channel and they spread the word quickly as whom to target. Historically, the fraud the big banks see has not trickled down to the smaller banks, but times are changing. So my guess is we will continue to see this trend for a little while before it levels out. As a long time bank fraud investigator, what is more interesting to me is what % of the SAR's filed, results in some form of federal investigation and prosecution. Across the entire spectrum from the analyst and investigator to law enforcement and FINCEN (and others not known) a lot of man hours are put into SAR filings and datamining. I can count one hand, ok maybe two, the number of follow up call's I received in all my years of filing SAR's By no means am I saying that SAR's are not relevant and are not an important part of an investigation, but I wonder if one of the main purposes is to track and report the fraud to FINCEN ( for later use), is there an easier more automated way to provide this data. SAR's are good if you think about the ability for link analysis and collusive networking detection, but all the details in the narrative, is it really needed? Is there another way to get the data to FINCEN which is less time consuming for the analysts and the investigators? As a former investigator we were always driven to find inefficiencies and make them efficient, work smart, (you know the drill) and the SAR was always one hurdle I came across that was a necessary evil of inefficiency. So as we see reports come out about # of SAR filings trending up or down, think of the time and money saved if it was only more efficient. So you love SAR's , an investigator, this is why I hated SAR's. "
David Hood
July 11, 2010 - 8:29 PM
"@nittany - Thanks for your comment! I can see why you would be frustrated by the lack of follow up on the SARs you filed. I know it is a lot of work to file SARs. My soft spot for SARs is mostly because it is one of the few data sources I've found that gives me a broad view of fraud trends. IMHO fraud metrics are sorely lacking and the industry as a whole would benefit from more access to data. "