Is anyone having trouble because they can't track for certain Red Flags, even though they have covered products?

For example: we can't monitor unsecured open-end lines of credit for use commonly associated with known patterns of fraud, material change in spending habits, material increase on use of available credit, or activity on a line of credit that has previously been inactive.

Our core processing systems offers NOTHING. What are other banks doing in these instances?

Would your BSA Software show spikes or other changes in your accounts? (regardless of type)

We are also struggling with this area. We are a small bank so we don't have BSA monitoring software or Fraud detection software. The only reports we get for BSA are large dollar or others aimed at structuring. We can monitor more closely overdraft reports but in an ideal world you would see the activity before it forced an overdraft. I also wondered how smaller banks were dealing with this issue.

Jamie

This would be a time to develop some sort of Velocity report. I'm sure if you talk to your IT or someone in charge of your Core Processing - they can come up with something.

For Example:

I want to see all accounts with and Increase or Decrease of activity from each month of 300%.


It would be something similar to a Kiting Report that I'm sure you pull already.

We too have had some red flags that we may not be able to have a way of tracking. At this point, we aren't including that as a red flag in our program. Remember, you aren't mandated to use any particular flag or even all of the flags in your progrom.

However, before excluding the flag, we are also looking at how likely it is to happen at our institution and also our past history. I would just be prepared to explain why you didn't include something or why you felt it wasn't relevant to your bank in case your examiner asks.

I share your concern. I have a 21-flag program. Many of the flags are combined, i.e., "address is not correct" is combined with "notice of address discrepancy" into one flag. But some flags (1 or 2) could get excluded in the long run. We're also considering including it as a flag, but having the sole planned detection method be "Employee observation." None of us are going to know if 50 different applicants provide the same phone number, but it is possible (though unlikely) that an accounts officer might.

http://www.bankersonline.com/forum/ubbth...e=2#Post1031196

Optional Red-Flaggers, Unite!
Be prepared for: Examiners who mistakenly believe you must include all red flags

You be the expert! Don't let them tell you what you do and don't have to include, because the regulation very clearly leaves that up to the institution.

We are going thru a 3rd party vendor to help us meet all of the 26 red flags. However, we are a $1.5B bank and I have heard of smaller ($500M and less) not including all the red flags. They are relying on their strict CIP and BSA Programs coupled with minimal ID theft victims over the previous 24 months.
I can't imagine trying to explain why we didn't cover them all but to each his own.