I'm posting this here where more people look as well as in security because I need some thoughts.

If you had a situation where a number of loan applications with fraudulent SSNs were referred over a short period of time from one broker/correspondent, it's pretty obvious the individual applicants (assuming they exist) and the broker must have been working together. They did not all come in on the same day...they were picked up individually and the pattern of the same broker/correspondent was noted.

Would you file separate SARs - one for each individual and one for the broker/correspondent - or one listing all borrowers and the broker/correspondent?

Thanks.

This is may be a judgment call, but my strong inclination would be to make a single filing including all the information. It appears that that broker is the hub and the applicants are just the spokes of the wheel. The intent would be to help FinCEN see the big picture; the pattern of activity.

If the SSNs are fraudulent, it is highly unlikely the individuals exist. Nevertheless, if you give FinCEN all the information it will still end up in their database, which is the ultimate objective.

When you tally your advice here and develop a plan, then I suggest you call FinCEN and tell them what you are going to do rather than ask them. (Most of us can agree to a plan easier than we can make one.) Make a memorandum of the conversation, enclosing a copy with the SAR and keeping the original as part of your supporting documentation.

I'm with Ken on this. Putting it all in one place should please FinCEN. It also helps you keep it together in your files.