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Before closing, the team discovers that a borrower asks whether the company will file a suspicious activity report. What is the safest compliant answer?

Correct Answer

D) Do not tell the borrower that a SAR may be filed

Lines 255-260; 31 CFR 1029.320 and final rule discussion of reports of suspicious transactions. SAR rules include confidentiality; the borrower should not be tipped off about a SAR filing or potential filing. Therefore, the correct response is "Do not tell the borrower that a SAR may be filed".

Answer Options
A
Ignore the issue if the borrower orally agrees to continue.
B
Proceed based only on borrower preference and document the file later.
C
Rely on sales practice rather than required verification, disclosure, or documentation.
D
Do not tell the borrower that a SAR may be filed

Why This Is the Correct Answer

Lines 255-260; 31 CFR 1029.320 and final rule discussion of reports of suspicious transactions. SAR rules include confidentiality; the borrower should not be tipped off about a SAR filing or potential filing. Therefore, the correct response is "Do not tell the borrower that a SAR may be filed".

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