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#1192899 - 05/29/09 06:40 PM Our Routing Number, Not our Bank - SAR?
Fallgirl Offline
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Fallgirl
Joined: Mar 2005
Posts: 432
Wisconsin
I am wondering if anyone would file a SAR in this case, my instinct is no. We had three checks hit our non-post report that came in through our correspondent bank. The checks have our routing number, but a different bank is listed on the check. The payee is not our customer and the maker is not our customer. The checks are less than $500 and we returned them. I don't think we need to file a SAR. Would any file a SAR in this case?

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#1192906 - 05/29/09 06:44 PM Re: Our Routing Number, Not our Bank - SAR? Fallgirl
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
You don't have a suspect; the filing threshold is $25,000 so no SAR. Unfortunately, in this circumstance you will probably be receiving these items for some time. Start a file...
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#1192920 - 05/29/09 06:56 PM Re: Our Routing Number, Not our Bank - SAR? Elwood P. Dowd
Fallgirl Offline
Gold Star
Fallgirl
Joined: Mar 2005
Posts: 432
Wisconsin
I didn't think I'd need to file a SAR at this time. I agree that we will probably be getting more of these checks. We received three today. I have my file started!

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#1192977 - 05/29/09 07:22 PM Re: Our Routing Number, Not our Bank - SAR? Fallgirl
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Keep a running tally and file a SAR when it crosses the $25,000 threshold.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#1192989 - 05/29/09 07:27 PM Re: Our Routing Number, Not our Bank - SAR? Fallgirl
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Keep a running tally and file a SAR when it crosses the $25,000 threshold.

You can also keep track of where the checks are being passed. If a pattern develops you can consider contacting the depositary bank(s) to give them a heads up (if they haven't awakened to the facts themselves). Also, the pattern(s) should be discussed in your SAR narrative, if filed.

Think about filing information on the checks -- especially if trends are seen -- with BOL CrimeDex.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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