I think you are building a case, BigBanknoob, for filing. When there's apparently little to no cash deposited to the business and significant cash amounts -- purportedly compensation or draws -- going into the owner's account, my SAR radar goes off. Given the many alternatives to cash payrolls, a bank should be seeing fewer and fewer situations in which compensation is paid in cash. There comes a point at which it is just too costly to dig and dig further to try to justify a transaction pattern like this, and filing the SAR may be the most reasonable decision. What you don't want is an examiner calling into question your SAR decision-making. The "Manual" notwithstanding, if your "no file" decisions appear to be weakly documented, you're inviting trouble.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8