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A loan officer at a non-bank lender realizes, on reviewing a $45,000 down payment, that the funds were moved through several accounts to hide their source. The suspect is identified. By when must the lender file a SAR?
A residential mortgage lender or originator must report a suspicious transaction involving at least $5,000 in funds or other assets, and must file the SAR no later than 30 calendar days after initial detection of facts that may constitute a basis for filing (31 CFR 1029.320(a)(2), (b)(3)). Only if no suspect is identified may filing be delayed another 30 days, to a maximum of 60. Cash is not required. Source: 31 CFR 1029.320 (as at 11 Oct 2026).
Using the $10,000 cash reporting threshold instead of the $5,000 SAR threshold.
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