On page 37 of the October '07 SAR publication (http://www.fincen.gov/news_room/rp/files/sar_tti_12.pdf), in a section where FinCEN is providing a more clear explanation of definitions, there is a section for "False Statements". The section outlines what would define a False Statement and trigger a SAR.

The last sentence of this reads: "The Application will trigger the statute even if the loan is not made". I'm trying to understand how this would apply. If the loan is not made, do we base it on the amount of the loan that was being sought?

So if we have two applications (one below the $5k threshold and one above it) where the applicant mis-stated their income, would we file a SAR on just the one above $5k or on both?

Thoughts?

Yes.

You would be allowed to file a SAR on each, but only required to file it on the one above $5,000.

Perfect!!