A mortgage loan originator notices that a borrower's income documentation shows round numbers with no cents (e.g., $5,000.00, $3,000.00) for multiple months of bank statements, and the borrower becomes evasive when asked about the source of these deposits. What is the MLO's primary obligation under BSA/AML requirements?
Correct Answer
B) Document the observations and report to the institution's BSA officer for potential SAR filing
Under the Bank Secrecy Act, suspicious activities should be reported to the institution's BSA officer who will determine if a Suspicious Activity Report (SAR) should be filed. Individual MLOs do not file SARs directly with FinCEN - this is done at the institutional level through proper channels.
Why This Is the Correct Answer
Under the Bank Secrecy Act, suspicious activities should be reported to the institution's BSA officer who will determine if a Suspicious Activity Report (SAR) should be filed. Individual MLOs do not file SARs directly with FinCEN - this is done at the institutional level through proper channels.
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