Scenario for you, FI has a loan to a customer made prior Patriot Act and did not verify valid social security numbers for the individuals. Comes back social security numbers are not for the people who have the loan. The individuals do not even have citizenship or visas. Where would he FI stand and what actions should be taken immediately.

BSA: SAR for identity theft (if SSNs belong to other people still alive) or "other" if false numbers or those of deceased persons. (In a large scale situation like this, at a former employer, we also notified Social Security).

Safety and Soundness: This will usually be a default under the loan terms. Your lending folks need to consult with legal and make some credit decisions like whether to call the loan.

The first thing I would do is have the lender contact the customer and ask for verification of the SSN.