I have an individual who applied and received a loan using an ITIN typed on Social Security card stock. The loan officer made a copy of the card for CIP and during a review someone tried to verify the number. Since it is an ITIN the SSA won't have any record of it and will say it is invalid. Somehow this guy printed up a Social Security Card with his name and ITIN and is using it. I have been tasked to file a SAR and I don't know what suspicious activity to call this??? Anyone else ever get one like this?

There are a number of Fraud categories on the SAR:
Commercial Loan Fraud
Consumer Loan Fraud
Counterfeit Instrument (Other)
Mortgage Loan Fraud

At one point in time a card was issued and it looked a lot like a Social Security Card. If it is not a legit. card how about Counterfeiting?

Just asking, why was the loan given before the number could be verified?

Why was a SS card used as Id?

SS was not ID but was collected as part of CIP for loan, as for why the loan was given (when credit report clearly indicated that the number was hinky) I do not know. This was done in 2006 and it was discovered during a review...... His DL is fine and he pays his loan very nicely, he just has the wrong piece of paper with his number on it!

Sounds like a 'G' to me, if it was consumer. "A loan extended to an individual for personal or household use that is obtained fraudulently. Incidents of consumer loan fraud primarily involve the submission of false or forged statements by loan applicants. "

I was looking this up and I noted that for "J Counterfeit Instrument" is states the manufacture, copy, reproduction. or forgery of an instrument with the intent to defraud a financial institution....Instruments could include notes, checks, securities, bonds, certificates and other negotiable instruments. Does this mean "negotiable instruments"ONLY? Or can I include the social security card there?

I was looking at the loan fraud and was getting the idea that it involved "making false statements" like the value of something or your salary, etc. Again, am I being too literal with the interpretation?

I would submit as G. You could probably submit as N or G, and I think you would be perfectly justified in either. However, I would suggest G, as you had issued the loan, and it seems more likely than not that that category is a better descriptor of the activity.

If the loan is still on the books, I would recommend contacting customer to find out what's going on. Even though the loan is current, if you suspect fraud, I'd want the loan off the books as well.

From the 7th issue of the SAR Activity Review:

A person who knowingly and willfully commits one of the following:
1. Falsifies, conceals or covers up by any trick, scheme or device, a material fact
2. Makes any materially false, fictitious or fraudulent statement or representation; or
3. Makes or uses any false writing or document knowing the same to contain any materially false, fictitious or fraudulent statement or entry.

The false statement "...must have been capable of influencing the bank's credit decision." So, if he had said "This isn't really my number...," would you have made the loan?

I too suggest you check n and the box for the appropriate type of loan fraud; e.g. consumer, and go on to what's next.