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SAR Triggered by Invalid SSN?
Answer by John Burnett and Ken Golliher, BOL Gurus
Question: Is it necessary to file a SAR if a person tries open an account with a Social Security Number that is reported as invalid due to death? There was nothing else suspicious about the person or transaction and his ID was reported as valid. We did not open the account.
Answer by John Burnett:
BIO AND CONTACT INFO
Whether this scenario crosses the line into identity theft is a judgment call. Often, it's not a matter of stealing an identity for the purpose of defrauding anyone. Instead, you may be facing what is euphemistically called an "undocumented alien" who has purchased the SSN to obtain work.
If this had been combined with an apparently bogus identity, including name and address, I'd be a lot more anxious to file a SAR.
Answer by Ken Golliher:
BIO AND CONTACT INFO
...and the dollar thresholds for SAR filing are not modified for identity theft. If you have a suspect, you file if there is $5,000 or more involved. If you do not have a suspect, the threshold jumps to $25,000. It seems axiomatic to me that, in the case of identity theft, you almost never have a suspect, only a victim.
First published on BankersOnline.com 9/15/03
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