I am having trouble coming to a decision on reporting kite suspects on a SAR. We are an FDIC bank.

Would it be fair to say that the best "litmus test" for distinguishing between mandatory filing and voluntary filing of a SAR would be the $5,000/$25,000 thresholds and insider abuse?

In other words:

Kite suspect aggregating less than $5,000 = voluntary filing

Kite suspect aggregating $5,000 or more = mandatory filing

Kite suspect is an insider (any amount) = mandatory filing

Your numbers and conclusions would be correct for all banks, regardless of their primary federal regulatory agency.

My assumption is you did not mention the $25,000 threshold because to have a kite and no suspect would be embarrassing! Nevertheless, that would also be mandatory reporting.