I have two questions:

1. If a customer withdraws more than $10,000 in cash and then tells the teller he is putting it in his safe deposit box because he does not trust the government, does that warrant a SAR? (He left several thousand in the account.)

2. If you discover a customer is using a personal account to run a small business, do you require the customer to open a business account? What if it is a d/b/a?

Thanks!

1. I would not file a SAR based solely on that info. I would review his accounts to make sure I didn't see anything that lead me to believe that he could be involved in something suspicious and may be fearing tax levies or garnishments.

2. A business should be properly documented as such (business license, entity papers, etc.) and you should be earning whatever fees you normally get from processing the additional transactions normally involved in a business relationship. If he is a sole proprietor, he will need to tell you whether he has a trade name. If so, account should be titled Joe Smith DBA Smith's Auto Sales. You will use his personal SSN for a sole proprietor account.

Thanks Brenda!