I have a situation just reported to me where an employee forged a customers signature on a bank form. Upon review it was evident that the signature did not match. This was reported to head of operations. The employee admitted signing the document and was made to go obtain a correct signature. It finally got reported to me. I began to file a SAR. Upper Mgmt says No. Bigger problem is Operations head and this employee are related. I think it still should be reported. What do I do?

A bank where I used to work had a lender forge a customer's signature on the insurance acknowledgement form only - and the lender was let go. This is fraud - plain and simple.

Maybe I'm reading to much into it, but if it was a telephone transfer for example that a teller should have written 'customer phone call' or something to that effect than perhpas training is an issue. If it was something like an address change or account opening item then I would agree with DS and file a SAR. Forgery is fraud and as an employee of a bank should be taken very seriousley.

It might be nice to know "what bank form". There might be a big difference between a form signing up for a newletter and a promissory note, for instance.

It was an address change form - elderly customer leaving the state. The employee forgot to have the customer sign before leaving the bank so the employee signed the customers name and turned it in. When reviewed it did not match and the employee admitted to signing it. The employee was forced to take another form to the customers house for a real signature. Security & Compliance was never informed until now - 3 months later.

Sounds like a training issue and not fraud to me.

I agree, this doesn't appear to be fraud. IF the customer had approved the change prior to the employee signing the form, I would document a disciplinary note to file. I would make it clear that any such action in the future would likely result in immediate dismissal.

"The employee was forced to take another form to the customers house for a real signature."

Someone trusted the same employee to take the form to the house and bring it back signed by the customer?!?!

In my world in South Florida, this would have been instant dismissal and a SAR.

Does seem to be an integrity/honesty issue, but at the same time, I'm not sure I would vote for dismissal either. 19-year-old uneducated tellers don't think the same way we do.

I'm sorry, but forging someones name should never be considered the right thing to do. I don't care how old you are.

No, it's never the right thing to do, but in this case, I wouldn't say it was criminal, and I wouldn't say it was an attempt to do anything more than be a little lazy and cut corners.

On the surface this may not appear to be criminal or an attempt to be anything other than lazy... but are you sure?

Sorry to play devil's advocate for a moment, but how do we know your ostensibly lazy, corner-cutting employee isn't actually part of an ID theft ring as the inside man? Was there anything (like a debit card or check order) sent out shortly before or shortly after this address change to the "new" address? Has the account been monitored closely for any unusual activity? Was the address changed again since this incident or shortly before this incident? Has the customer been contacted? Is the customer actually at this "new" address?

This isn't just laziness... it's signature fraud, which is a crime. Any crime by an insider is required to be SAR'ed. This isn't just some internal "sign up your email address" form, this is a change of address form, which should be a very closely monitored control point of your operations department. Your bank's ID Theft/Red Flags policy most likely touts your change of address forms requiring customer signature as the way you control the file maintenance changes and the integrity of your data. It's part of the heart and soul of your BSA program. If you have employees forging these, you have no control and no integrity in your system.

Have you gone back and analyzed all change of address forms that this employee may have been involved with to determine if these are all actual customer signatures? I think there's a lot more investigating to be done. Especially since the employee fessed up pretty quickly, I'd be suspicious what *else* they may have done that they are now attempting to not draw attention to.

If this decision were mine to make, I would definitely recommend immediate termination of this employee, retraining of all other employees, and a SAR filed immediately: you're already technically outside your timeframe window for SAR filing on this.

Great Points WildBlueYonder

I would question "intent." Because the customer made the original request, this employee had no intent to defraud the customer or the bank. Certainly, you could not get a prosecution on such a case. Was the employee stupid? Yes! Criminal, no!

I'll just say one more thing before people start recommending I wear a tinfoil hat to combat my paranoia:
How do you know the customer made the request if their signature isn't on the form? If an independent employee also saw the customer in the bank that day and heard the entire discussion and remembers that they were requesting an address change 3 months later, then ok maybe there was no intent. If we're just taking the word of the person who signed the customer's name after the fact and then was sent to the customer's house alone, I'd worry whether the customer even knows about this address change.

Possibly not a concern, but possibly it is. It's pretty shocking what some people will do to be sneaky. I used to be so naive and believe every story told to me. Not anymore.

I agree with WBY all the way. After all, filing a SAR isn't about researching a law enforcement case, it's noting something potentially suspicious and then allowing law enforcement to determine if it's criminal.

And I don't subscribe to the notion that all SAR'd employees must be terminated. I would explain in the SAR that she has been retrained and her other recent changes of addresses were scrutinized for anomalies, and none were found; and that I contacted the customer and verified he/she requested the change of address in the first place (assuming all that is the case).