But $4,500 is under the SAR reporting threshold. IMHO, the account should be monitored to see if the customer starts conducting transactions that would be indicitive of structuring.
He may have received some bad info along the lines of "If the bank records your transaction, they file it with the IRS and that could trigger an audit." He may also be afraid of identity theft.
There is a reason the SAR reporting threshold was set at $5,000, and when the industry starts to voluntarily lower that threshold, we could really set ourselves up for program failure later on.
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CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'