Question:  One of our loan officers just left our bank to work for a competitor.  We have learned that she copied and took customer information with her.  What should we do?

Answer:  Make a demand for the return (or certifiable destruction) of the records.  If they are not returned or properly disposed of, then file a SAR.  According to the regulatory panel at the recent Texas Association of Bank Counsel Annual Convention, this officer's action presents several legal problems.  First, it is a taking of property (customer information) owned by the bank.  Second, it results in a breach of the bank's GLBA procedures protecting customer information.

Remember that you CANNOT disclose the filing of the SAR outside of the bank's board of directors, and they must keep it confidential.

Arguably, you should file the SAR whether or not the records are returned/destroyed.  In any event, do NOT warn the ex-officer that you are filing!