Banks: Renew Your Suspicious Activity Reporting Forms
Published Date: 2/20/2025
Notice
Summary
The Office of the Comptroller of the Currency (OCC) is asking banks and financial institutions to help renew their paperwork on security devices, suspicious activity reports, and anti-money laundering programs. They want to make sure these rules stay clear and effective without adding extra hassle. If you’re involved, get your comments in by April 21, 2025, to help shape the process—no new fees or big changes, just a smooth renewal.
Analyzed Economic Effects
4 provisions identified: 0 benefits, 4 costs, 0 mixed.
OCC renews paperwork collection (OMB 1557-0180)
If you run a national bank or Federal savings association, the OCC is seeking renewal of its information collection identified by OMB Control No. 1557-0180 and is asking for comments by April 21, 2025. The OCC estimates 1,036 respondents and a total annual burden of 1,266,791 hours for this collection; responses are required only when the collection displays a valid OMB control number.
Security officer and written program requirement
If you operate a national bank or Federal savings association, 12 CFR 21.2, 21.4, 168.2, and 168.4 require you to designate a security officer who must develop and administer a written security program and report at least annually to the board of directors; the substance of that report must be reflected in the board's minutes.
Written BSA compliance program required
Under 12 CFR 21.21, national banks and Federal savings associations must develop, maintain, and continuously administer a written Bank Secrecy Act (BSA) compliance program that is approved by and reflected in the minutes of the board of directors.
Suspicious Activity Report filing and 5‑year retention
Banks and Federal savings associations must file Suspicious Activity Reports (SARs) and keep a copy of any SAR filed plus the original or business-record equivalent of supporting documentation for five years. The OCC notes an estimate of about 1 hour of burden per SAR filed.
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