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#2211293 - 04/16/19 09:29 PM Product Type - SAR
Bec Offline
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If one were to file a SAR that included activity on an agriculture note would one pick the product "bonds/notes" or would they select "other" and fill in "agriculture note" What about a commercial note? I know that would not necessarily be commercial paper but would it fall in the bonds/notes category or would you have to fill in the Other?
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#2211445 - 04/17/19 07:27 PM Re: Product Type - SAR Bec
TryingtoComply Offline
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It's a loan, right? I believe there is an option for commercial/business loan.
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#2211483 - 04/17/19 10:44 PM Re: Product Type - SAR Bec
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There is an option for Commercial Paper which I believe are short term notes which are unsecured? The other option is a commercial mortgage but the commercial loans here are not secured by real estate. Am I correct on those interpretations?
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#2211518 - 04/18/19 03:37 PM Re: Product Type - SAR Bec
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bump
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#2211523 - 04/18/19 04:16 PM Re: Product Type - SAR Bec
bcompliance Offline
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I think you could check commercial paper and explain what type of loan in the narrative. I could also see checking other and listing what you suggested. I'd just pick a way and be consistent going forward when you file on these types of loans.
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#2211576 - 04/18/19 08:31 PM Re: Product Type - SAR Bec
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thank you for your suggestions!
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#2211583 - 04/18/19 09:25 PM Re: Product Type - SAR Bec
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If the suspicious activity involves a wire that was going to be used to pay off notes, would you include the notes at all? Or would it only be the wire and leave the product types blank?
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#2211605 - 04/19/19 01:36 PM Re: Product Type - SAR Bec
ColoradoAML Offline
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I would include the notes.

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#2211617 - 04/19/19 01:57 PM Re: Product Type - SAR ColoradoAML
bcompliance Offline
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Originally Posted By ColoradoAML
I would include the notes.


I agree
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#2211692 - 04/19/19 08:26 PM Re: Product Type - SAR Bec
Bec Offline
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Another Product Type question. Is a certificate of deposit included in the Deposit Account for product type? For some reason I am equating deposit account with transaction account and a CD is not a transaction account. How do you typically report these types of accounts when they are involved in a SAR?
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#2211707 - 04/22/19 01:16 PM Re: Product Type - SAR Bec
bcompliance Offline
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I have chosen to include those as a deposit account and will be consistent going forward. I don't think there is any formal guidance.
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