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#1983067 - 12/15/14 05:43 PM SAR
Banker57 Offline
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Joined: Jul 2010
Posts: 439
Minnesota
Customer deposits payroll checks into account. Perhaps 95% of the checks written out of this account are written payable to themself and either cashed or deposited at one other local bank. This is the majority of the entire account activity. Kiting? SAR worthy?

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#1983069 - 12/15/14 05:44 PM Re: SAR Banker57
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,627
Galveston, TX
What relationship does the depositing of payroll checks have with the fact that they get cash out of the account.
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#1983076 - 12/15/14 05:54 PM Re: SAR Banker57
Banker57 Offline
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Joined: Jul 2010
Posts: 439
Minnesota
There was kiting suspected previously, that activity stopped. Not sure if the current activity warrants ongoing monitoring or other action.

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#1983081 - 12/15/14 06:03 PM Re: SAR Banker57
rlcarey Online
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rlcarey
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Posts: 79,627
Galveston, TX
If I don't control or if I am not in collusion with someone that controls the accounts from which the deposits are coming from, how could this ever be considered a kite????
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#1983109 - 12/15/14 06:54 PM Re: SAR Banker57
HappyGilmore Online
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Posts: 19,529
Pulling people out of the ditc...
Originally Posted By: Want2komply
There was kiting suspected previously, that activity stopped. Not sure if the current activity warrants ongoing monitoring or other action.


okay, i'm going to ask the obvious question - if you suspected kiting previously, why is the account still open? and now you have additional or ongoing monitoring on this account because of previous suspected activity. Is it worth maintaining the relationship?
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#1983126 - 12/15/14 07:25 PM Re: SAR Banker57
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Quote:
Customer deposits payroll checks into account.


His payroll checks or payroll checks payable to others?
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#1983186 - 12/15/14 08:54 PM Re: SAR Banker57
Midwest BSA Offline
Member
Joined: Sep 2014
Posts: 54
We have a very similar situation. Guy owns business (that account is at another bank). The majority of checks into his account with us are payroll checks payable to others and signed over to him. Checks out are mostly payable to cash and deposited at the other bank.

I'm not comfortable with the activity and want to close the account.

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#1983188 - 12/15/14 08:58 PM Re: SAR Midwest BSA
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
In all likelihood, your and want2comply's customers are operating an unlicensed check cashing business... Ask them, then show them the gate.
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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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