Are these wholesale situations were you believe that there is fraud involved or is this an oversight or bookkeeping problem with the dealer? If this is wholesale fraud, why is the customer still a customer? Why is the bank not physically holding all the titles to the vehicles and only releasing them on sale? If that is happening, the dealer is in violation of State laws in most states. This shows that there are more weaknesses in your processes than just worrying whether or not when to file a SAR and puts your bank at financial risk. I have seen situations like this cost banks big bucks.
KB - great minds think alike - you just type faster than I do