If a car dealer sells inventory that is used as collateral and makes no payment to the bank. Should a SAR be filed?

I attended the MN Banker's Compliance Module last week on BSA/AML et al last week. The FDIC Examiner specifically said that collateral sold out of trust was SAR reportable. He used it to illustrate to banks that maybe file 1 SAR a year - the question came up relating to examiners citing SAR threshholds.

Long story to a YES answer

Yes, this would definitely be SAR reportable. In fact, we have just been cited by the OCC during our exam for not filing a SAR for just this reason. If you take a look at the SAR Activity Review - Trends, Tips, & Issues - Issue 7 - August 2004, it gives a listing of each of the types of SAR reportable activity types and definitions or samples of each type. Under the Commercial Loan Fraud category on the SAR, this type of activity with dealers is specifically referenced. You can find that document on the Fincen.gov web site.

That is what I thought. Thanks for the input.