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#1616041 - 10/14/11 06:50 PM Loan Transfers due to Fraud (Procedures)
pweiss Offline
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Joined: Mar 2011
Posts: 103
CA
Hello,

How does your institution handle requests by customers to transfer their loan numbers due to fraud or lost/stolen ID.

Are there any regulation requirements/best practices? Is the loan file notated, do you need a written request from the customer, or do you just change the loan number at the request (no notating or documentation required)?

I am wondering incase an auditor asks why the loan number was changed.

Thanks,
_________________________
Phil Weiss, CAMS

My opinions are my own and not that of my employer.

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Lending Compliance
#1617133 - 10/18/11 07:53 PM Re: Loan Transfers due to Fraud (Procedures) pweiss
pweiss Offline
100 Club
Joined: Mar 2011
Posts: 103
CA
Anyone?
_________________________
Phil Weiss, CAMS

My opinions are my own and not that of my employer.

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#1617197 - 10/18/11 08:43 PM Re: Loan Transfers due to Fraud (Procedures) pweiss
MyScamper Offline
Gold Star
Joined: May 2006
Posts: 452
Between here and there
We had a situation where a number of HELOCs were compromised by a hacker. We changed all the account numbers to protect against unauthorized draws.

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#1617270 - 10/18/11 10:23 PM Re: Loan Transfers due to Fraud (Procedures) MyScamper
pweiss Offline
100 Club
Joined: Mar 2011
Posts: 103
CA
Did you notate the file explaining why the numbers changed?
_________________________
Phil Weiss, CAMS

My opinions are my own and not that of my employer.

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#1617312 - 10/19/11 05:19 AM Re: Loan Transfers due to Fraud (Procedures) pweiss
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Follow your normal authentication requirements for the request. I strongly suggest an audit trail with explanations on changing the numbers. How would anyone reviewing the file know what occurred if you did not? Someone could think there was fraud, or an error unless there is an explanation and notes regarding who authorized the change.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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