Thread Options
#2070354 - 03/22/16 02:03 PM denial reason for suspicious activity of customer
Dodge Offline
100 Club
Joined: Mar 2010
Posts: 238
Existing customer applied for a new loan. Even though, they are existing customer our policy is to obtain a new Driver License when the one on file has expired and the customer is requesting a new account. The customer stated that they couldn't get one, not even a state issued ID.

This situation has raised a red flag and we believe the loan should be denied. What would be the reason for denial, "unable to verify identification" ?

Return to Top
Lending Compliance
#2070360 - 03/22/16 02:33 PM Re: denial reason for suspicious activity of customer Dodge
osucpa Offline
Diamond Poster
Joined: May 2011
Posts: 1,400
Did you ask them why they could not obtain a DL or state ID card?

Return to Top
#2070368 - 03/22/16 02:46 PM Re: denial reason for suspicious activity of customer Dodge
Dodge Offline
100 Club
Joined: Mar 2010
Posts: 238
Yes, it was due to his green card expired and he hasn't renewed it... Supposedly, it has been expired for a while.

Return to Top
#2070369 - 03/22/16 02:47 PM Re: denial reason for suspicious activity of customer Dodge
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,398
Florida
If the person is an existing customer, you have the ID, and IMHO you cannot deny for unable to verify identification. May try something else, like no current identification available, but as a current customer, they are identified. Current customer = having an existing, not former account. (I know it is mixing up KYC, CIP, ECOA, etc.)

I'd go with osucpa, it may be the license was revoked, or something similar.
_________________________
Integrity. With it, nothing else matters. Without it, nothing else matters.

Return to Top
#2070376 - 03/22/16 02:56 PM Re: denial reason for suspicious activity of customer Dodge
MyBrainHurts Offline
Platinum Poster
Joined: Feb 2010
Posts: 960
Illinois
If his Permanent Resident Visa (green card) is expired, he cannot legally work in the US, so how can he repay the loan without illegal employment? That's enough of a reason for me. He needs to sort out his immigration status, and then apply for a loan.

If he would come back with a valid green card, though, wouldn't that be adequate as ID?
_________________________
I thought getting old would take longer.

Return to Top
#2070379 - 03/22/16 03:04 PM Re: denial reason for suspicious activity of customer Dodge
Dodge Offline
100 Club
Joined: Mar 2010
Posts: 238
He is construction worker and has a ITIN number. We have his current tax returns which were filed after his ID & green card expired.

Return to Top
#2070382 - 03/22/16 03:09 PM Re: denial reason for suspicious activity of customer Dodge
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,398
Florida
You then appear to have the ID, but the bank cannot verify his ability for repayment due to continued employment without the green card.
_________________________
Integrity. With it, nothing else matters. Without it, nothing else matters.

Return to Top
#2070384 - 03/22/16 03:11 PM Re: denial reason for suspicious activity of customer Dodge
#Just Jay Offline
10K Club
#Just Jay
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
IRS doesn't care about legal status, they just want income. Thus his filing a tax return means nothing.

You need to assess the risk of his current murky legal status, the risk of him either being suddenly deported, going underground or leaving, the risk of loss should this happen, as well as your current policies lending and legal status, and go from there.
_________________________
I don't repeat gossip, so listen closely...

Return to Top
#2070694 - 03/24/16 02:29 PM Re: denial reason for suspicious activity of customer Dodge
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,281
Galveston, TX
There are several incongruities in this story. If you policy is that an existing customer present a valid current ID and they don't have one, then of course you can deny them. How do you know they are who they say they are?

He is construction worker and has a ITIN number.

In order to get a green card, you have to have a SSN.

Tell him to cough up the $450 and get his card renewed, as he is legally not able to work in the US so his future income is in question and come back and apply.

If you know who the employers is, you might want to consider filing a SAR.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2071043 - 03/25/16 07:28 PM Re: denial reason for suspicious activity of customer Dodge
*W*W* Offline
Platinum Poster
Joined: Feb 2010
Posts: 835
If the bank were to make the loan knowing that the individual's green card was expired, I would be concerned that the funds used to close on the loan and to repay the loan are from illegal proceeds and thus money laundering until he straightens out his green card issue. Is that a stretch??
_________________________
Live Like No One Else!
CRCM

Opinions expressed are my own and do not reflect the views of my employer.

Return to Top

Moderator:  Andy_Z