We have a customer who asks for random people's help by having them issue checks to him and he provides them cash (more than the amount on check) in return. For us, it's suspicious but don't know what is the best reason to put in the SAR?
Scenario- A customer receives foreign wires for "family support." This customer also received an unsecured loan for a purpose of "family support".
The customer withdrawals most of the account funds at casinos in cash and then makes cash deposits after winning money. The lender doesn't have a
concern on the loan side. What is your opinion on filing a SAR?
If we are still delivering disclosures and statements in paper form, do we have to be concerned with E-SIGN or UETA?
If a SAR is submitted on the due date using an automated system is it considered to be on time or does it have to be accepted by FinCEN by the due date.
I have a customer who was a partial recipient of loan proceeds. He asked that his part be disbursed in several cashier's checks made payable to his son. The son then would come in and cash the checks separately. Some needed a CTR and some not. I'm trying to decide if this warrants the filing of a SAR on either the father, the son or both?
Recently, an LO with poor judgment ran a credit report on a woman after an application from a man who claimed to be her husband, but key here is he was not going to be a co-borrower, he said his credit and income were bad, only his "wife" would be on the loan. Statement of Credit Denial went out, Risk Based Pricing Notices went out, woman is very upset. We ran her credit and says she is not married. Obviously, we goofed and there is peril here. What about joint applications where we speak to only one party and ask permission for pulling credit? Do we have to ask both parties if it is OK to pull credit?
It has been determined that a customer has fraudulently indicated employment on a loan application. At the time of the application he was employed, but at closing he had been terminated and did not notify the lending officer of his change in status. Other than a SAR, what else should I pursue to report this situation?
I have a home improvement loan which is secured by real property and is being used for college tuition. Is this HMDA reportable? The funds are not being used for repair or home improvement at all.
A customer inquired about a credit line deed of trust using his residence as collateral. He wasn't ready to submit an application, he just wanted to know what would be involved. The subject of appraisals came up and he asked who our approved list of appraisers were. I told him if and when he was prepared to submit an application to come back in. Two weeks later while I was on vacation, he came back and left an appraisal preformed by one of our approved appraisers. On the front page it said that the appraisal had been ordered by the bank. Can I accept this appraisal or has it been tainted?
If I suspect money laundering in a commercial loan account, to the point where I am going to submit a SAR, what options do I have for closing that account? Assume that I strongly suspect money laundering, but cannot prove it definitively.