We have a scenario where a customer is delinquent on their loan and we are attempting to collect. During these attempts it was discovered that the collateral has been seized by law enforcement due to fraud that the customer has engaged in. This was a consumer loan. Customer also had business accounts and loans with us. Legal has requested that we do a review of all open and closed accounts to look for suspicious activity.

Do we have an obligation to review closed accounts/paid loans? The business accounts/loans were closed in 2014. If this is the case, how far back to we look - since it was opened? Just doesn't seem logical to me.

I would look for a reasonable amount of time and if I found something I didn't like I would keep looking.

Good luck

Thanks for the suggestion. I went read through the indictment and then reviewed the accounts for the timeframes that were mentioned in there until current.

We have reviewed accounts connected to the fraud ring and discovered suspicious activity. Our attorney was in contact with a law enforcement official during this process. The contact with the LEO is what prompted our review (they sent us a copy of an idictment which listed our collateral as being seized). Would you include the LEO's contact information on the SAR? I'm going to ask our attorney also, I am trying to get an idea of what others would do in my shoes (I'm leaning toward yes but there is an internal debate).

There is a section on the SAR where you would list the LEO's information and I agree that this would be a good thing to include. If another Law Enforcement Agency picks up this SAR they now have a contact point to see how the investigation is going.

While establishing the lookback period might be subjective, the advice was rock solid.