We have a new teller that cashed a $11,500 check for a non-customer. She verified the customers ID and got all the required information for the CTR except for his SSN. We have called the individual and he refuses to give us the SSN. How do I proceed with the CTR and is a SAR necessary?
Should a SAR be filed for debit card fraud when a police report has already been made?
Should we file a SAR in the following situation? - A customer asks "Who can see wires?" and "Will the government know about this wire?" Nothing else about the client or the transaction is suspicious or requires either a CTR or a SAR.
Recently, a customer made three deposits totaling $125,000 in cash. Two were for $50,000 and one was for $25,000. The customer is retired. Should we file a SAR?
Recently in dealing with a non-resident alien, an ITIN was presented at the time of account opening. After researching on the irs.gov website and calling the IRS, I was told that an ITIN can only be used to file a US tax return. It is not to be used for any other purpose, including opening a bank account. In your question and answer page about non-resident aliens it mentions and ITIN can be used . Please clarify.
I am an internal auditor and currently reviewing our bank's procedures related to the Bank Secrecy Act. I have two questions concerning structuring of deposits. <ol><li>Assume structuring of deposits is identified and known structuring is occurring. My understanding is that a SAR would always be completed, but our compliance officer is indicating a SAR may or may not be filed. If he or she is correct, please explain why we would not file a SAR if structuring is identified. <li>My understanding is that known structuring requires a SAR and, therefore, the Board (in our case the Board includes management personnel) would be informed. Our compliance officer is indicating that structuring would only be reported to management and the Board if a SAR was filed. Doesn't structuring always require a SAR and, therefore, Board notification? </ol>
For HMDA reporting purposes, if a bank knows that information submitted by a prospective borrower on a standard residential loan application is not correct, can the bank modify the application itself or just leave it as is, which means the HMDA reporting would not be accurate? I am a regulator asking this question on behalf of one our bankers. He explained that his bank has noted errors and/or discrepancies throughout the application form, including: <ol><li>The borrower refinancing a present residence marks on the declarations that he or she has had no ownership interest in a property in the last three years. <li>The borrower indicates he or she has not filed bankruptcy in the past seven years but a credit report and public records indicate there has been a filing. <li>The borrower indicates he or she is both a U.S. citizen and a permanent resident alien. <li>A borrower indicates he or she intends to occupy the property as a primary residence but elsewhere in the application it is evident the property is for investment purposes. </ol>Perhaps the question about what to do on a loan application when these instances are discovered needs to be answered separately for each instance. I will relay your response(s) to my banker.
I have been newly appointed to a bank Board of Directors and have little banking knowledge. I have been approached by one of our tellers with a concern about CTRs. It seems that on a regular basis (couple times a month) a customer comes into the bank with two checks around $6500.00 each and has them cashed. One is in his name the other is in his father’s name. Each time he is alone and walks out of the bank with around $13,500.00 cash. My teller is afraid that this is a BSA violation. Is this a violation? Would this at least warrant a Suspicious Activity Report?
Who in the bank signs a SAR filed on an insider? Is it the BSA or Compliance Officer or the CEO? I have been told that my internal auditor (who is actually at our sister bank) is the only one who can sign, is this correct?
When I complete a SAR, it goes to our BSA compliance officer. The SAR is then edited and sent to FinCEN. It has come to my attention that the SAR does not bear the same content (and is not as informative for law enforcement) as the one I wrote. The edited version is not relayed to the writer and therefore when the FBI speaks to the writer, the information may not match what was in the SAR which can cause a conflict for the writer due to bank procedures allowing only what was in the SAR to be discussed with law enforcement. Can the bank get in trouble for sanitizing the SAR to the point where the information is barely useful?