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This section summarizes the relevant supervisory history, the Consent Order's SAR-related findings, and the roles of the various regulatory and consulting entities whose expectations the framework must satisfy

Each QA reviewer must possess at least five years of BSA/AML experience, including demonstrated expertise in SAR investigation and filing

A fundamental principle of the QA Framework is that QA reviewers must not have been involved in the original investigation or filing of any SAR that they are assigned to review

A Deficient rating indicates that the SAR contains material quality issues that must be investigated and remediated

RCA Accountability The following timeline and accountability requirements govern the RCA process: • Individual RCAs must be completed within 10 business days of error identification

• Thematic and systemic RCAs must be completed within 20 business days of the triggering condition being identified