Scenario 30: Which of the following is most likely to trigger a 'Suspicious Transaction Report' (STR) to FINTRAC?

Question: Scenario 30: Which of the following is most likely to trigger a 'Suspicious Transaction Report' (STR) to FINTRAC?

Answer options:

• A client making a large cash down payment for an expensive home, with easily verifiable income. ✅ A client repeatedly making small deposits just under the reporting threshold, using different accounts, with no clear legitimate source of funds.
• A client asking many questions about mortgage rates.
• A client choosing a 5-year fixed mortgage over a 3-year variable mortgage.

Correct answer: A client repeatedly making small deposits just under the reporting threshold, using different accounts, with no clear legitimate source of funds.

Explanation: Layering tactics, such as structuring transactions (smurfing) to avoid reporting thresholds, are a common red flag for potential money laundering and would definitely warrant filing a Suspicious Transaction Report. The lack of a clear legitimate source of funds further raises suspicion. The correct answer is "A client repeatedly making small deposits just under the reporting threshold, using different accounts, with no clear legitimate source of funds.". This capacity-fill scenario 30 reinforces the same competency for the mortgage-broker bank and follows the certified explanation standard.