John Doe deposited $11,000 into his consumer checking account. The Bank placed a large item exception hold on $6,000 of the deposit and a case by case hold on $4,800 of the deposit.

The day after the deposit Mr. Doe withdraws $200 that was subject to next day availability.
On the day the case by case hold falls off Mr. Doe withdraws $4,800.
On the day the exception hold falls off Mr. Doe withdraws $6,000.

On the surface this appears to be structuring withdrawals. However, based on my interpretation of the situation, Mr. Doe simply wanted the cash immediately, but because of circumstances he had to wait out the holds.

I don't feel that this is structuring and that a SAR isn't warranted.

Do I still need to go to the trouble of documenting the case for my SAR Committee so I can prove to the BSA examiners that I noticed this and considered it? ***Sadly, I feel the answer is yes, but I'm hoping that there will be a unanimous outpouring of "no, that's just extra work and no examiner wants you to waste time on obvious garbage".****

Thanks in advance.

It doesn't appear to be structuring to me. If it is, then the bank helped by putting the holds on in the way you did!

But, I do think it would be best to put it on your log and document why it's not suspicious. We all know it will get questioned!

I would add that whether or not you present it to your SAR committee may depend on how your process is structured. In our bank, this case would not be presented to the SAR committee, but the reason not to present would be documented and retained. We get a lot of referrals and do a lot of research, but the majority never make it to committee. The research is documented, and available for any regulator to review.

Your mileage may vary if your established process is to provide all researched items to your SAR committee for a final decision.

Thank you.

The SAR Committee is new since I've taken the BSA seat in August, so I'm still in the process of defining it.