An MLO notices that a real estate agent has been consistently referring clients who provide similar documentation patterns that appear suspicious, but no individual transaction clearly meets the SAR threshold. How should the MLO handle this pattern recognition?
Correct Answer
A) File a SAR based on the aggregate suspicious pattern across multiple transactions
SARs can and should be filed based on patterns of suspicious activity across multiple transactions, even when individual transactions may not meet the threshold. Financial institutions are required to identify and report suspicious patterns that may indicate money laundering or other illegal activities under BSA requirements.
Why This Is the Correct Answer
SARs can and should be filed based on patterns of suspicious activity across multiple transactions, even when individual transactions may not meet the threshold. Financial institutions are required to identify and report suspicious patterns that may indicate money laundering or other illegal activities under BSA requirements.
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Previous Question
A borrower's mortgage broker suggests refinancing their current 5.5% loan to access equity for home improvements. The new loan has a 5.75% rate but includes a prepayment penalty, higher fees than disclosed initially, and the cash-out amount is $15,000 less than promised due to 'additional required reserves.' This situation best exemplifies:
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A mortgage broker discovers that a borrower has provided falsified employment verification but learns the borrower recently lost their job and is desperate to avoid foreclosure on their current home. The broker should: