Fourteen filers submitted approximately 30 SAR-SFs on a network of investors across the United States for suspicious trading activities involving several CMBS worth billions of dollars. Myriad pricing and trading issues were evident in these SARs. Suspicious activities included securities fraud (16 percent of reports), significant wire or other transactions without economic purpose (14 percent), pre- arranged or other non-competitive trading (11 percent), wash or fictitious trading (9 percent), embezzlement/theft (7 percent), money laundering/structuring (7 percent), suspicious documents or identification (5 percent), forgery (4 percent), and other (26 percent). Filers cited frequent movement of securities with face values.
