> Question number three was from someone who asked if they should go
> to the bank and take out their cash and how to do it. I advised
> them to call the bank and speak to someone who they are familiar
> with about what they would like to do. I mentioned that any
> withdrawal over $10,000 will likely trigger a SAR (Suspicious
> Activity Report) and that will be on file in Federal government
> database in Detroit for something like 7 years. I advised them to
> speak with the rep at the bank to confirm that. I warned them not
> to go to various branches and try to withdraw amounts less than
> $10,000 in order to avoid an SAR as that is called "Structuring"
> and is a federal crime. I told them that the bank would not
> likely have the amount of cash on hand that they were looking to
> withdraw or may not be wanting to give it up due to liquidity
> concerns, but that perhaps the bank could order the cash and have
> it available for pickup the next day. They aborted the
> conversation before I was able to explain that Federal Reserve
> notes are partially backed by junk now that the Fed has exchanged
> their good collateral out through the TSLF, and that t-bills are
> probably the better option. Although, at this late date I am not
> really sure whether there would be enough time to establish a
> treasury direct account and I do not really know whether having a
> bank hold treasury bills is 100% safe. I think so but am just not
> sure as I never considered that option.
This is correct for the most part. But any withdrawal of cash over $10,000 triggers a CTR (Currency Transaction Report), not necessarily an SAR. The CTR is automatic. As far as the SAR, policies are probably a moving target. Engaging in structuring will almost certainly generate an SAR, I would think. As I remember, that is what supposedly put Spitzer under the microscope to begin with.