We have an individual customer that is a tax preparer. He only has personal accounts with us. He has made several large cash withdrawals over the last two weeks that have triggered CTRs. Now we are up to $160k since the first of December. I talked with the loan officer since the customer is drawing off a HELOC and doing a cash withdrawl each time he draws from the HELOC. The customer did this last year but I was told he was remodeling his office. The loan officer has now told me our customer will estimate his clients tax returns and give them a loan based on what their return will be once he files their taxes. This seems a little shady on several levels. My main concern, is he considered a money services business? We have checked the website and he is not registered. He used to cash these refund checks and was registered but has stopped for some reason. Also, would this be considered a payday loan service? I assume he would be charging a fee? My other concern is why is he getting money through his personal HELOC and not a business account/loan. Any thoughts would be greatly appreciated.

Check your State law, many States require RAL lenders to be registered or licensed.

He's not an MSB and *if* he's being honest he might be a refund anticipation loan lender as RLCarey mentioned.

But those are lesser concerns. This is not at all consistent with how a legitimate tax prep operates. It could be a lot of things: a bust-out scheme, refund skimming, or some good old-fashioned laundering. But it's not normal.

If you have certain tools to look up bankruptcy filings, tax liens, etc. you should see if there's any derogatory information out there.

Are these tax refunds being deposited into his personal account?