May I have some input on how other institutions handle HELOC Fraud? This is not covered by Reg E because it is not a "deposit" account. The information I am finding on line is that the cuatomer is liable and each financial institution responds to the customer differently. Then there is the SAR consideration for mortgage fraud. Any help would be appreciated.

Can you explain a little more about the fraud without going into too much private information. I'm a little unsure how to respond.

Customer received a statement and there was a draw for $2,133.00. They said they did not authorize the draw.

Can you track where the funds went?

We are working on that right now. I think the struggle is our Deposit Operations oversees all REG E claims. This (Loan Fraud) has been put into the hand of loan operations. They are looking for regulations to guide them. Personally I think the process should be assigned to Security and Fraud Prevention.

Follow 1026.13, Open-end billing error resolution.

(a) Definition of billing error. For purposes of this section, the term billing error means:

(1) A reflection on or with a periodic statement of an extension of credit that is not made to the consumer or to a person who has actual, implied, or apparent authority to use the consumer's credit card or open-end credit plan.

RR is correct. You have to handle this under the Reg. Z error resolution rules.

Thank you....I was stuck in Reg E