A covid-19 related SBA loan was credited to a personal account and the customer seems to be using the funds for business and personal expenses. For the SAR filing, should the suspicious activity amount include the entire loan amount or just specify the amount that's been misused? Thank you for your help.

I think it's best to file on what you can prove is the suspicious activity. If the SBA gave approval, I don't know that is the amount I'd use.

For example, if the business is a "Hats and Baskets" business but you see gambling transactions from those funds, those are unauthorized expenses.

I'm surprised that the SBA funds were allowed to go into a personal account. Ours had to be the name of the business applicant had to match the name of the account.

Thank you for the advice. SBA loan had the payee's name matching the personal accountholder's name so the SBA did give the loan approval perhaps as a sole proprietor, but the customer is using some of the funds clearly for personal expenses. So the question is for $100K loan, the customer has misused $80K, then would the suspicious dollar amount be just $80K or should it be $180K to include the $100K as a possible loan fraud as well since the customer's business can't be verified either... Well I guess I will just have to file based on my assumptions...

I would list the amount of funds that you believe were used inappropriately.

Customer could have received a $100,000 SBA loan and used $80,000 to gamble away, but the rest of the $20K could have went towards business related spending. List what you think appears to be suspicious at the time of filing. If you feel like more suspicious activity/spending happened after you filed, then you need to add that to your 90 day review and refile.