Scenario:
Customer deposits two checks into a new account. The total deposit exceeds $5,000 but both checks are returned; returned reasons are "Refer to Maker" and "NSF". Then, five days after opening, account begins to receive ACH debits totaling $49,000 from another financial institution.
For purposes of a SAR, would the above scenario be considered "Check Fraud" and "Other - ACH Fraud"?