I instituted a procedure to review and revalidate the original file documentation for seriously delinquent borrowers and short sale requests. In one particular case, a borrower that had a loan for several years(a realtor) relocated to another state and took out an another mortgage, consequently falling behind on his mortgage with us. He continued to try and sell the propety and eventually did (our bank approved a short sale after getting an updated appraisal). It doesn't appear to be a buy and bail because fundamentally he didn't walk, and in a buy and bail scenario the consumer fraud or misstatment occurs when he files a false application with a new lender to induce them to make the loan; it doesn't appear to be a short sale scam because of the relo circumstance and fair market price. I don't see a SAR filing in this scenario but our compliance person is suspicious because he is a realtor. Any insight? What am I missing? Thanks.