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#2247586 - 01/13/21 02:11 PM Loan Customer Not Behaving
Brandi S. Offline
Junior Member
Joined: Jun 2020
Posts: 41
Good morning all,
We have a business loan customer who is depositing between $8,000 & $9,000 in cash into their loan sweep deposit account every so often. When they do these deposits they initiate an extra payment toward their loan. The extra payment is always close to the amount of the cash deposited. On this customers risk assessment it states they were not going to deposit cash into this account and the account will be funded by 100% checks. In actuality the account is funded by rental ACH deposits. While I am already on their tail, my question is...do I alert the loan officer to this activity? He seems to never think his customers are doing anything illegal.

Thanks in advance

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#2247588 - 01/13/21 02:48 PM Re: Loan Customer Not Behaving Brandi S.
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 78,584
Galveston, TX
So - someone needs to ask for their rent rolls, since they have a loan with you and compare the total deposits to the expected rent payments. Then is it is just a matter of confirming that they accept rent payments in cash.
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#2247618 - 01/13/21 06:17 PM Re: Loan Customer Not Behaving Brandi S.
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,133
New York City
You should let the loan officer know. While this could be suspicious activity and warrant a SAR I'm wondering if this could be a credit issue as well?
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#2247624 - 01/13/21 06:46 PM Re: Loan Customer Not Behaving Brandi S.
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 78,584
Galveston, TX
So - someone needs to ask for their rent rolls

Yes i.e., someone - equals loan officer in this case.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2247627 - 01/13/21 06:56 PM Re: Loan Customer Not Behaving rlcarey
Brandi S. Offline
Junior Member
Joined: Jun 2020
Posts: 41
Will do, I just pulled the rent roll from the loan file. Thanks.

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#2247833 - 01/19/21 09:26 PM Re: Loan Customer Not Behaving Brandi S.
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,544
Cape Cod
What about the elephant in this room? If you get current rent roll information and verify it, and the monthly deposits are high by the cash deposits you mentioned earlier, what concerns might you have? Could there be some money laundering going on?
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