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#1780105 - 01/25/13 10:38 PM Account Takeover
TXBSA Offline
100 Club
Joined: May 2006
Posts: 170
We recently had a customer report that their cash managment system had an account takeover. We were able to verify that a fraudulent ACH batch had been created and were able to stop it before funds left. Now we have to contend with the SAR filing.

On the new SAR form we have a few questions:

1. Would the bank be the selling or paying location? (I have seen that we can leave it blank, but we prefer to fill it in if we can)

2. On Item #39: Should we leave that blank? The funds were coming from a deposit account.

3. On Iten # 40: Would it be more accurate to check Funds transfer or Other: ACH?

Thanks in advance for any help!

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#1780234 - 01/28/13 03:29 PM Re: Account Takeover TXBSA
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,873
Cape Cod
I don't believe that the SAR involves the sale or payment of a product or instrument, so item 52 (paying or selling location) should be left blank.

For item 39, also a blank. There was no product involved

For item 40, check funds transfer, and also check box "z" and insert ACH in the "list below"
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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