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#1485837 - 12/27/10 07:50 PM Modification/Foreclosure Rescue Scam
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
I'm filing a SAR on a company that duped our customers out of $1,500 by claiming to be able to assist in the modification of their $120,000 mortgage loan. What amount do I put on the SAR as the amount of the suspicious activity?
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Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

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#1485976 - 12/28/10 09:48 AM Re: Modification/Foreclosure Rescue Scam Kelsey D
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Your use of terminology suggests you have already looked at the FinCEN Guidance, and realized it does not specifically address your issue. Regardless, they clearly want this activity reported without regard to the threshold amounts.

If you use $1500, the SAR is voluntary. If you use $120,000, the SAR is mandatory. (Either way, you have complied with the substance of the guidance.) If the phone was broken, I would use the latter figure. Otherwise, I would call FinCEN to avoid the sharpshooting reviewer who can't find anything else and who prefers form over substance anyway.
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#1486089 - 12/28/10 03:44 PM Re: Modification/Foreclosure Rescue Scam Elwood P. Dowd
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
Yes, I read the guidance. Thanks for your advice, Ken. I'll give FinCEN a call.
_________________________
Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

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#1486160 - 12/28/10 04:26 PM Re: Modification/Foreclosure Rescue Scam Kelsey D
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
In case anyone is interested, the answer I received from FinCEN was to include the amount of the mortgage and any other accounts that could have been compromised, i.e., if the perpetrators were trying to get information about the deposit accounts, include that as well.
_________________________
Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

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#1745068 - 09/27/12 11:02 PM Re: Modification/Foreclosure Rescue Scam Kelsey D
SonnyGirl Offline
Gold Star
Joined: Feb 2004
Posts: 391
I was searching for some information on modification/foreclosure scams and found this although it is old. I believe we may have a similar situation. We have a customer who says he paid $2000 for a loan modification, haven't confirmed that yet. The "company" sent us a fax with the customer's authorization requesting information. I have googled the company name, tried to find them on whitepages.com, no luck. Nationwide Legal Group in Tustin CA, anyone heard anything about this company or related scams? I am not really familiar with legitimate companies or how they work but this does sound fraudulent, doesn't it? There shouldn't be upfront fees, should there? The customer is struggling to make payments now and he gives them $2000?? Doesn't make sense at all....

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