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#1196253 - 06/04/09 08:43 PM File another SAR?
dg Offline
Platinum Poster
Joined: Jan 2005
Posts: 811
Pacific NW
I filed a SAR 2 months ago on a customer that was taking large cash advances from his construction loan acct. He claims he was paying sub's. I noted structuring and possible loan fraud because he also was purchasing cashiers checks from the proceeds that were payable to a car salvage dealer.

Since the filing of the initial SAR a very large deposit was made into the construction account. The customer used a small amt of those proceeds to payoff the construction loan and asked if he could take $200,000 out in cash. We told him we were unable to do that so now he is frequenting the branch and withdrawling $10,000 at a time.

The question is, does this warrant another SAR filing or should I wait and file a continuing SAR?

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#1196260 - 06/04/09 08:48 PM Re: File another SAR? dg
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
The activity has changed; you file a new SAR now. (That's based on previous calls to the FinCEN Helpline.) In your narrative for this one describe the prior activity, say what has happened since, and provide enough information where they can locate the prior SAR. Then, describe the current activity.

If either type of activity continues, then the date of this SAR is your first and you will follow-up within 90 days.

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#1196302 - 06/04/09 09:16 PM Re: File another SAR? Elwood P. Dowd
dg Offline
Platinum Poster
Joined: Jan 2005
Posts: 811
Pacific NW
Should my total dollar amount (box 34) include the $200,000 request in cash or just the amount that he has actually taken?

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#1196360 - 06/04/09 11:22 PM Re: File another SAR? dg
dg Offline
Platinum Poster
Joined: Jan 2005
Posts: 811
Pacific NW
The SAR line instructions say: Item 34 - Dollar amount involved - Enter the dollar amount involved in the suspicious activity. If less than a full dollar is involved, round it to the next highest dollar.
An aggregated total of all transactions for multiple or related suspicious activities by the same individual or organization within the same reporting period may be shown in this field. The break- out of this total may then be listed in Part V.

So do I put in line 34 the amount of the suspicious activity or the actual transactions? What are all of you entering suspicious or actual? Someone must have suggestion out there.

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#1196415 - 06/05/09 10:53 AM Re: File another SAR? dg
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
You report the suspicious amounts. If you think the $200,000 deposit was suspicious, report that amount. Your narrative can discuss the deposit and the withdrawals.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
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