Product Type - SAR

Posted By: Bec

Product Type - SAR - 04/16/19 09:29 PM

If one were to file a SAR that included activity on an agriculture note would one pick the product "bonds/notes" or would they select "other" and fill in "agriculture note" What about a commercial note? I know that would not necessarily be commercial paper but would it fall in the bonds/notes category or would you have to fill in the Other?
Posted By: TryingtoComply

Re: Product Type - SAR - 04/17/19 07:27 PM

It's a loan, right? I believe there is an option for commercial/business loan.
Posted By: Bec

Re: Product Type - SAR - 04/17/19 10:44 PM

There is an option for Commercial Paper which I believe are short term notes which are unsecured? The other option is a commercial mortgage but the commercial loans here are not secured by real estate. Am I correct on those interpretations?
Posted By: Bec

Re: Product Type - SAR - 04/18/19 03:37 PM

bump
Posted By: bcompliance

Re: Product Type - SAR - 04/18/19 04:16 PM

I think you could check commercial paper and explain what type of loan in the narrative. I could also see checking other and listing what you suggested. I'd just pick a way and be consistent going forward when you file on these types of loans.
Posted By: Bec

Re: Product Type - SAR - 04/18/19 08:31 PM

thank you for your suggestions!
Posted By: Bec

Re: Product Type - SAR - 04/18/19 09:25 PM

If the suspicious activity involves a wire that was going to be used to pay off notes, would you include the notes at all? Or would it only be the wire and leave the product types blank?
Posted By: ColoradoAML

Re: Product Type - SAR - 04/19/19 01:36 PM

I would include the notes.
Posted By: bcompliance

Re: Product Type - SAR - 04/19/19 01:57 PM

Originally Posted By ColoradoAML
I would include the notes.


I agree
Posted By: Bec

Re: Product Type - SAR - 04/19/19 08:26 PM

Another Product Type question. Is a certificate of deposit included in the Deposit Account for product type? For some reason I am equating deposit account with transaction account and a CD is not a transaction account. How do you typically report these types of accounts when they are involved in a SAR?
Posted By: bcompliance

Re: Product Type - SAR - 04/22/19 01:16 PM

I have chosen to include those as a deposit account and will be consistent going forward. I don't think there is any formal guidance.