A mortgage loan originator discovers that a borrower has structured multiple cash deposits just under $10,000 to avoid CTR reporting requirements. This practice is known as:
Correct Answer
A) Structuring or smurfing
Structuring (also called smurfing) is the practice of deliberately conducting transactions in amounts just under reporting thresholds to avoid CTR filing requirements. This is illegal under the Bank Secrecy Act and is a red flag requiring a SAR filing.
Why This Is the Correct Answer
Structuring (also called smurfing) is the practice of deliberately conducting transactions in amounts just under reporting thresholds to avoid CTR filing requirements. This is illegal under the Bank Secrecy Act and is a red flag requiring a SAR filing.
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A Loan Estimate shows an origination charge of $2,000. At closing, the actual origination charge is $2,150. Assuming no valid changed circumstances, what is the maximum total that can be charged without violating TRID tolerance rules?