Skip to content
BOL Conferences
Thread Options
#1237244 - 08/21/09 08:02 PM Do I file a SAR?
bsarockstar Offline
Junior Member
Joined: Aug 2009
Posts: 32
We received a call from another FI stating that they received a letter from the IRS because a check they deposited did not get credited to the right person. It turns out that it was a $300 stimulus check (deposited 7/2/2008) deposited at their ATM. Our customer was the naughty person. He took someones check and forged their signature and made the deposit at an ATM, which was then credited to his checking account. We called are customer and basically told him that we knew what he did and he admitted to this - he thought is was really meant for him (he thought we were stupid). He paid back the money to us and I paid the FI that had to return the money to the IRS. My first thought is to do a SAR. Now I'm second guessing myself since it's only $300 and no one is out any money. The FI said that the IRS didn't care if the check was forged - they just want their money back.

Any thoughts? I have the SAR completed. I just don't know if I should send it.

Return to Top
BSA/AML/CIP/OFAC Forum
#1237264 - 08/21/09 08:11 PM Re: Do I file a SAR? bsarockstar
ATLbanker Offline
Gold Star
Joined: Sep 2005
Posts: 332
Georgia
It is under the reporting threshold. If you know the suspect, the dollar amount has to be $5,000 or more to be reportable.

Return to Top
#1237266 - 08/21/09 08:11 PM Re: Do I file a SAR? bsarockstar
JacF Offline

Power Poster
Joined: Nov 2001
Posts: 6,719
PA
Unless the forger was an insider, the mandatory reporting threshold has not been met. You may file a SAR (IMO, I see little value in doing so), but are not required to do so.

Return to Top
#1237282 - 08/21/09 08:20 PM Re: Do I file a SAR? JacF
bsarockstar Offline
Junior Member
Joined: Aug 2009
Posts: 32
I knew that it was under the threshold, but the way examiners talk, we should file on every suspicious activity we encounter. They act like the thresholds don't really count.

I feel kind of stupid filing because the customer is young and stupid-period.

Thanks for the input!

Return to Top
#1237457 - 08/22/09 09:47 PM Re: Do I file a SAR? bsarockstar
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
"They act like the thresholds don't really count. "

Just tell them to go pound rocks when they act like this. There is no cause for examiners to act like this and it is an easy argument to win.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  Andy_Z