Customer requests a $2500 loan for debt consolidation today.
Loan officer remembers doing a $3,000 debt consolidation loan for this customer 3 months ago for a 3 month term (said loan has been paid off). Loan proceeds were deposited into customer's checking account. LO tries to verify any debt consolidation paid out from the checking. No debt payoff found, but noticed that customer has withdrawn $22,000 cash within last 5 months. Loan officer runs customer's credit and did find that the customer paid down a credit card $4,000 since the last time the credit bureau was ran 3 months ago. Thus, no proof if loan proceeds were used for intended purpose or not (hopefully lesson learned by LO).
LO asked customer which creditor was going to be paid with this loan. The customer stated that really the money is for carpet.
Upon questioning the customer regarding the $22,000 cash withdrawals in the last 5 months, it was determined that he is a victim of Financial Elder Abuse. The customer was needing the loan so that "Jane Doe" would be able to come into town. The customer has been withdrawing cash below BSA recordkeeping requirements and depositing the cash into the account of "Jane Doe" at XYZ Bank.
Question - In the SAR for "Jane Doe" - do I reference anything in regards to the fraudulent loan request since it was going to be used to supply her with more cash?
Question - Since the Loan request was only $2500 - do I just do a SAR Not Filed?
Any help would be appreciated, it gets confusing when it all ties together and knowing when and how to separate it.