This is probably not the right forum for this question but i figured somone could help me out. We have a consumer loan and the borrower says he makes sufficient income but it is unverifiable. Its over $100,000 he says but im just not sure how you couldnt verify that income. Its not reported on his taxes and he has no pay stubs. Does this mean he only recieves cash? Im not sure please let me know what you think?

I know that we have to verify income if the loan is sold. Gone are the days of stated income loans.

Sure sounds like he's a cash employee.

Here's a question - If he's telling you that he makes this much $$ and is not reporting it on his taxes, is that SAR-able? Is that a word? Would you file a SAR if you know or have suspicion that he is evading taxes? Or am I reaching too much here?

When it comes right down to it for banking purposes, we always had a policy that if income wasn't on a tax return, it didn't happen. It was like a tree falling in the woods when no one was around. If someone wanted to cheat on their taxes, the penalty was that they couldn't use that as income at our bank to justify a loan.

As far as the SAR, if you can't verify the income, how can you suspect tax evasion? Is re depositing unsubstantiated amount of cash into his accounts. If so, I would approach it from that angle.