[b]Just wanted to get an insight on how other FIs are handling accounts like this. We have a real estate attorney who's using his personal account to factilitate what appear to be real estate closing transactions. Of course, he should be using either his attorney business and/or IOLTA accounts. Would you file a SAR based on just this factor? I don't think the customer will stop doing this any time soon.

Your customer will stop using his personal account for business transactions very shortly after you tell him to stop it...

I see no basis for a SAR, but find it hard to imagine that anyone at a closing table would accept a check drawn on a personal account as "good funds." I suggest you look at the checks themselves to be sure he hasn't ordered some that say something else. At this point, your concern is that you are on notice the account is not being used as your due diligence information would have led you to believe and you need to do something about it.