The bank has a customer that filed and then withdrew a complaint about a $6500.00 withdrawal from one of his accounts. His daughter impersonated her mother to make a telephone transfer. Is a SAR required. We have not suffered a loss and have not involved law enforcement since the claim was withdrawn.
I am curious to your policy on telephone transfers. Do you allow telephone transfers between accounts that are not owned by the same person? You stated that the daughter impersonated the mother. Were the funds transfered from the mothers account to the daughters account? Does the mother have ownership rights on the daughters account? Is this normal practice? Do you do call backs to make sure the transfer was authorized?
Our bank has experienced similar situations. We went to call backs when there is a telephone transfer that occurs between different account holders.
The parents have dropped the complaint. The teller making the transfer did make and error when making the transfer between unrelated accounts. He has been transfered to a back office function. I'm leaning toward filing a SAR especially since the examiners may pull this file randomly and question us as to why we didn't file one. Agree?
I would not file a SAR. It was your teller error. It was between family members who have chosen to not press charges. Presumably there has been no loss. What would the SAR say?
Remember, you don't have to have a loss to file a SAR. That's one of the things that got AmSouth in trouble. I'm not saying to file or not to file, but don't make that your basis to rely on.
The family discovered a second telephone transfer and again decided to not file an official complaint with us. I did file a SAR since the examiners have the right to look through my files during an exam. I'd rather be safe that sorry.