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A borrower pays the loan application fee with multiple money orders, each just under $3,000, totaling $8,500. The borrower states they 'don't trust banks' and prefer money orders. This scenario primarily raises concerns about:

Correct Answer

A) CTR threshold avoidance through structuring

Using multiple monetary instruments just under the $3,000 reporting threshold may indicate structuring to avoid CTR requirements under 31 USC 5324. This pattern of breaking up transactions is a red flag for potential money laundering activity.

Answer Options
A
CTR threshold avoidance through structuring
B
Inadequate CIP documentation
C
Violation of TILA disclosure requirements
D
RESPA prohibited payment restrictions

Why This Is the Correct Answer

Using multiple monetary instruments just under the $3,000 reporting threshold may indicate structuring to avoid CTR requirements under 31 USC 5324. This pattern of breaking up transactions is a red flag for potential money laundering activity.

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