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#2131474 - 05/23/17 02:27 PM SAR on Commercial Loan Officer
Anonymous
Unregistered

If a commercial loan officer emailed confidential bank information to himself before resigning what category would you use? To make matters worse, he did this via unsecured email.

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#2131493 - 05/23/17 03:28 PM Re: SAR on Commercial Loan Officer Anonymous
HappyGilmore Offline
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Joined: Jun 2004
Posts: 19,296
Pulling people out of the ditc...
with this limited information, I'd suggest other
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#2131494 - 05/23/17 03:38 PM Re: SAR on Commercial Loan Officer Anonymous
Anonymous
Unregistered

The confidential information included tax returns, loan applications, w2's, financial statements of customers, etc. Basically entire loan files.

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#2131500 - 05/23/17 03:49 PM Re: SAR on Commercial Loan Officer Anonymous
Rocky P Offline
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Joined: Jun 2003
Posts: 7,208
Florida
Not the brightest crayon in the box.

If not done so, check fidelity coverage, Ethics and/or HR policy. Contact new employer and enjoin them from contacting customer via legal.
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#2131503 - 05/23/17 04:00 PM Re: SAR on Commercial Loan Officer Anonymous
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,371
Bloomington, IN
The person committed theft. That's what I would put on the SAR.

https://www.nowsecure.com/blog/2010/08/31/departing-employees-and-data-theft/
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2131507 - 05/23/17 04:08 PM Re: SAR on Commercial Loan Officer Anonymous
kw004h Offline
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Joined: Nov 2009
Posts: 219
Chicagoland, IL
Based on the definitions here (from FinCEN but from a long time ago), does Identify Theft fit? (I'm emphasizing the word "transfers" : https://www.fincen.gov/sites/default/files/shared/sar_tti_07.pdf#page=45

"A person who knowingly transfers or uses, without lawful authority, a means of identification of another person with the intent to commit, or to aid or abet, any lawful activity that constitutes a violation of Federal law, or that constitutes a felony under applicable state or local law."
Last edited by kw004h; 05/23/17 04:10 PM.
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#2131519 - 05/23/17 04:32 PM Re: SAR on Commercial Loan Officer Anonymous
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 77,009
Galveston, TX
You need to immediately inform your regulator about this situation regardless of what check box you choose for your SAR. They have in the past and will prosecute this person to include a life-time ban from banking. This is a very serious data integrity/theft situation.
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#2131528 - 05/23/17 05:12 PM Re: SAR on Commercial Loan Officer rlcarey
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 9,987
Toano, VA
Originally Posted By rlcarey
a life-time ban from banking
Right. Regardless of what you decide to report, this needs to happen. This guy should never work for another bank.
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#2132604 - 05/31/17 11:12 PM Re: SAR on Commercial Loan Officer Anonymous
SMQ, CRCM Offline

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SMQ, CRCM
Joined: Apr 2001
Posts: 4,828
Between the lines
Definitely inform your regulator asap.
On the SAR, I would look at section 35 Other Suspicious Activities and check
j Misuse of position or self dealing
q Unauthorized electronic intrusion

I let them sort it out. And there was a bank a few years ago that made the headlines when the lender and his assistant emailed customer lists to themselves prior to resigning from the bank.
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#2132652 - 06/01/17 02:21 PM Re: SAR on Commercial Loan Officer Anonymous
HRH Okie Banker Offline
Power Poster
Joined: Jan 2003
Posts: 3,070
Oklahoma
Most definitely inform your regulator as others have said. I've seen this happen in the past and it is not only taken very seriously you very probably will see this escalated all the way to Washington.

Start making notes now. See if you can put together a spreadsheet of what and when was emailed - down to customer names and identify the documents - tax returns, appraisals, financial statements, title work.... The regulators not only see the offence of taking customer info but also in taking info belonging to the bank. You should also attempt to do a print history to see if you can identify days/weeks of any abnormal heavy printing and identify the customer and document types (maybe the printing of trial balances).

Take "depositions" now of anyone involved in the identification of the issue so nothing is forgotten by the time you are interviewed by your regulator.
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#2132677 - 06/01/17 03:11 PM Re: SAR on Commercial Loan Officer HRH Okie Banker
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,208
Florida
" You should also attempt to do a print history to see if you can identify days/weeks of any abnormal heavy printing and identify the customer and document types (maybe the printing of trial balances). "

If you have a network printer, most save documents to a printer hard drive. Your printing programs might be able to tell what documents were printed and by whom. Electronic copies may still be on the hard drive to ID.
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