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#11877 - 03/01/02 03:36 AM How many SARs to file
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
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?


Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy

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#11878 - 03/02/02 05:39 AM Re: How many SARs to file
JacF Offline

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Joined: Nov 2001
Posts: 6,719
If confronted with the same situation, I would try to get as much information on a single SAR as possible. As the reporting guidelines ask that SAR's be filed within 30 days of noticing the activity, use that 30 days to collect as much information as possible, and include all applications from that period in a single report. If you get additional applications after your reporting date, compile that information for a 90 day followup.

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#11879 - 03/08/02 08:51 PM How many SARs to file
elcinoca Offline
Platinum Poster
Joined: Jan 2002
Posts: 537
Elizabeth City, NC
k--I concur with JacFSB

I believe you hit the nail on the head in your first sentence--"assuming they exist." One broker, numerous applications and numerous fraudulent's not likely that each application is coming from distinct individuals. Can the broker really recruit that many dishonest people at one time? Hmmmm.....

File one SAR and document the Who-What-When-Where of all the supposed "borrowers" on one form. Best of luck!

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