File a SAR on a Loan Officer?

A senior loan officer has given some large loans that are contrary to bank policy and were not approved in a loan committee meeting. The loans have since gone bad and have been written off as a loss to the bank. This loan officer has subsequently resigned. A lawyer has suggested that we should send a SAR on the loan officer because of the resulting losses and the fact that he wrote the loans outside of bank policy. My thought is that although it was not according to policy, it was also not illegal activity and therefore does not warrant a SAR.