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#1892488 - 01/31/14 03:15 PM Which Box to Check on SAR Re Loan Application?
downbytheriver Offline
Member
Joined: Jan 2008
Posts: 51
Georgia
I'm a little confused concerning the new suspicious activity types. I have a customer who applied for a mortgage loan providing false documentation concerning employment. Would I need to check consumer loan, provided questionable or false documentation, and residential mortgage? Previously we only checked boxes concerning a loan if the applicant had actually been approved. Our customer was denied because the fraud was caught up front. I can't seem to find any updated definitions for the additional types that have been added. Any guidance would be appreciated.

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#1892509 - 01/31/14 03:40 PM Re: Which Box to Check on SAR Re Loan Application? downbytheriver
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Whether a loan was approved or denied was never a factor in whether a SAR was required.

Although it's been promised, there is no interpretive information on all the new boxes. So, the critical instruction on the FinCEN SAR is "Check all that apply." My suggestion is that you write your narrative and, when you have it nailed, then go back and check the boxes that are consistent with your story.

Based on what you've said here, I would check:

31(d) Consumer loan

34(z) Fraudulent documentation

38(z) False statements on application

Opinions on the specifics may vary, but you're on the right track.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#1892528 - 01/31/14 04:05 PM Re: Which Box to Check on SAR Re Loan Application? downbytheriver
downbytheriver Offline
Member
Joined: Jan 2008
Posts: 51
Georgia
Thanks Ken for your advice.

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