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#2089653 - 07/25/16 02:44 PM To file or not file a SAR?
Calmeida12 Offline
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If an individual files a credit card application and the bank determines that it's a fraudulent application, is the bank responsible for filing a SAR? Thank you.

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#2089655 - 07/25/16 02:47 PM Re: To file or not file a SAR? Calmeida12
Elwood P. Dowd Offline
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If the fraudulent information was capable of affecting the bank's credit decision and the threshold amount is met, yes. Whether or not the loan was actually made is irrelevant.
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#2089695 - 07/25/16 04:32 PM Re: To file or not file a SAR? Calmeida12
Calmeida12 Offline
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In this case, there is no threshold because the application process was never finished. The credit report was pulled and it was noticed a red flag and when the applicant was contacted he stated that he never applied for the credit card and that there have been other credit card applications submitted on his behalf.

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#2089719 - 07/25/16 05:27 PM Re: To file or not file a SAR? Calmeida12
rlcarey Online
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Galveston, TX
What was the credit limit applied for??
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#2089809 - 07/25/16 08:22 PM Re: To file or not file a SAR? Calmeida12
Calmeida12 Offline
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The suspect did not specify a limit, he was just interested in getting a credit card. But if the victim would have been approved under normal circumstances, he would have gotten a $10,000.00 credit limit based on the credit report, salary and underwriting criteria.

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#2089824 - 07/25/16 08:52 PM Re: To file or not file a SAR? Calmeida12
Elwood P. Dowd Offline
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If I understand your fact situation, you are talking about identity theft, not credit fraud.
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#2089825 - 07/25/16 08:57 PM Re: To file or not file a SAR? Calmeida12
Calmeida12 Offline
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Yes, it's identity theft on accredit card application.

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#2091750 - 08/05/16 11:59 AM Re: To file or not file a SAR? Calmeida12
Pat Patriot Act Offline
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Originally Posted By Calmeida12
The suspect did not specify a limit, he was just interested in getting a credit card. But if the victim would have been approved under normal circumstances, he would have gotten a $10,000.00 credit limit based on the credit report, salary and underwriting criteria.


IMHO, you're best off using the $10,000 figure as the total of the attempted transaction, regardless of whether it was specifically requested by the fraudster. With that being said, it sounds like you do not have an identified suspect and thus would not be required to file due to the dollar amount being under the $25k "no suspect" threshold.

In terms of voluntarily filing or not, I'd base the decision off how much useful data you anticipate you can provide to law enforcement. Even without substantial identifying information, if the Bank received a good amount of other information that could LE to a suspect than go ahead and file. For example, if the application was received on a mobile device and the bank has the phone number, carrier id, device info, and geo-location data; that could be extremely helpful. Conversely, if you received limited information, it might not be all that useful of a SAR.
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