In a training scenario, a borrower asks whether the company will file a suspicious activity report. What action best follows the rule?
Correct Answer
B) Do not tell the borrower that a SAR may be filed
Why this is correct: The rule from 31 CFR 1029.320 requires that information about a SAR filing remain confidential. In a training scenario simulating a borrower's question, the action that best follows the rule is to maintain this confidentiality by not disclosing any information about a potential or actual SAR. Therefore, the correct action is to "Do not tell the borrower that a SAR may be filed." Why the other choices are wrong: The choice to "Handle records, reports, and required notices with a sales script rather than the required file action" is wrong because using a sales script to address a SAR inquiry could lead to an improper disclosure; the required action is specific and non-disclosure. The choice to "Use the policy exception request as a reason to postpone the required compliance step" is wrong because SAR confidentiality cannot be postponed; it must be applied immediately when the question is asked. The choice to "Skip the rule because the policy exception request appears routine" is wrong because no exception allows skipping the core confidentiality requirement of SAR rules. Exam tip: In any scenario—real or training—the rule is simple: never tip off a borrower about a SAR. There are no exceptions for routine processes or scripts.
Why This Is the Correct Answer
The correct response is "Do not tell the borrower that a SAR may be filed". SAR rules include confidentiality; the borrower should not be tipped off about a SAR filing or potential filing.
Why the Other Options Are Wrong
Option A: Handle records, reports, and required notices with a sales script rather than the required file action.
Handle records, reports, and required notices with a sales script rather than the required file action. is not correct because it bypasses the rule supported by the explanation.
Option C: Use the policy exception request as a reason to postpone the required compliance step.
Use the policy exception request as a reason to postpone the required compliance step. is not correct because it bypasses the rule supported by the explanation.
Option D: Skip the rule because the policy exception request appears routine.
Skip the rule because the policy exception request appears routine. is not correct because it bypasses the rule supported by the explanation.
Memory Technique
For SAR questions, no tipping is almost always the tested ethics point.
Exam Tip
For SAR questions, no tipping is almost always the tested ethics point.
Common Mistakes to Avoid
- -Customer service transparency does not include disclosing SAR activity to the subject.
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