Question: We offer credit cards and handle quite a few applications that appear to be fraudulent or incomplete in one way or another. Experience with the credit card program tells us that most of these applications are from customers who are hoping that we won't notice something negative in their credit history. Do we need to report each one of these on a SAR?
Answer: Ordinarily, we follow the rule of when in doubt, file. However these credit card applications aren't really representative of fraud. They are more likely to represent high hopes of the uncreditworthy. For that reason, we believe that it is not necessary to file a SAR on each and every one of these. However, you should maintain a high standard of alertness if you decide not to file SARs on all these hopeful customers. Your decision to do this should be balanced by a capability to watch application patterns for fraud with immediate action to file SARs when patterns of fraud or specific frauds are detected.
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