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Ethics & Fraudmedium17% of exam

An MLO discovers that a colleague has been accepting cash payments from borrowers to overlook documentation discrepancies. The colleague is terminated, but no borrower has suffered financial harm. What is the SAR filing requirement?

Correct Answer

B) SAR must be filed for insider fraud regardless of customer financial impact

SARs must be filed for insider fraud involving institution personnel, regardless of whether customers suffered financial harm. The BSA requires reporting of suspicious activities that may involve violations of law, including bribery and corruption by employees, even when customer losses are not apparent.

Answer Options
A
No SAR required since no borrower was harmed financially
B
SAR must be filed for insider fraud regardless of customer financial impact
C
SAR only required if the cash payments exceeded $5,000
D
Internal disciplinary action satisfies the reporting requirement

Why This Is the Correct Answer

SARs must be filed for insider fraud involving institution personnel, regardless of whether customers suffered financial harm. The BSA requires reporting of suspicious activities that may involve violations of law, including bribery and corruption by employees, even when customer losses are not apparent.

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