SAR on Customer Trying to "Game" ChexSystems?
Answer by Ryan Rasske, BOL Guru (Guru BIOS ) Question: If a customer manipulates his SSN/TIN in an effort to hide a record on ChexSystems, does a SAR need to be filed? Would it matter if the SSN/TIN was corrected and the account kept?
Answer:
Any time a customer manipulates his or her SSN/TIN to deceive a financial institution it would be considered suspicious and support a SAR filing. What was the intent of the customer? Obviously it was to hide his true identity and conduct financial transactions under a false SSN/TIN. Even though you apparently identified and corrected the issue, it doesn’t erase the fact that this customer still committed the act.
Also, be sure this discrepancy and its final outcome is properly documented as part of your CIP record retention and Identity verification process. If asked, your regulators will want to know how the discrepancy was discovered and resolved.
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