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#373699 - 06/16/05 03:16 PM SAR - False Statement ?
lisa Offline
Gold Star
Joined: Aug 2001
Posts: 264
Gainesville, TX USA
How many of you would file a SAR on a loan applicant that provided you with a SSN that has been reported "not issued as of March 2005"?

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#373700 - 06/16/05 03:21 PM Re: SAR - False Statement ?
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,638
Galveston, TX
Was it done with the intent to defraud the bank? Is the customer just dyslexic? I think it takes a little more research to make a determination and it will be a case-by-case call.
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#373701 - 06/16/05 07:00 PM Re: SAR - False Statement ?
renniks Offline
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renniks
Joined: Sep 2003
Posts: 2,162
New England
In the lending world, if we found out for sure that the SSN was truly fake, stolen, or invalid, we would consider it an attempt to defraud the bank. We would then deny the loan and file a SAR.

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#373702 - 06/20/05 09:49 PM Re: SAR - False Statement ?
LoisLane Offline
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LoisLane
Joined: Oct 2001
Posts: 1,570
Wisteria Lane..
I'm looking for a similar conversation that I just read today and this is the closest that I could find with the search.
The information I'm looking for was about filing a SAR and someone maybe John? Andy? Randy? Jim? referenced some of the definitions that are SAR violations like "Commercial loan fraud".
Obviously that's not on this discussion-- but what I wanted to ask is where can I find the definition for "commercial loan fraud", "mortgage loan fraud" etc.
I checked out FinCEN with no luck (although I did find an interesting power point there that I hadn't seen before).
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#373703 - 06/20/05 10:04 PM Re: SAR - False Statement ?
MyKidsMom Offline
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MyKidsMom
Joined: May 2004
Posts: 635
TEXAS
You will also see this "warning" on ITIN numbers.

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#373704 - 06/21/05 12:08 AM Re: SAR - False Statement ?
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,638
Galveston, TX
Lois,

I think you are looking for the definitions that Ken so graciously provided in this thread:

Unreported Income
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#373705 - 06/21/05 01:20 PM Re: SAR - False Statement ?
LoisLane Offline
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LoisLane
Joined: Oct 2001
Posts: 1,570
Wisteria Lane..
Randy and Ken. Thanks so much. Yes, this is the information I was looking for (I thought I had re-looked at everything from yesterday trying to find it).
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#373706 - 06/21/05 02:07 PM Re: SAR - False Statement ?
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Lois,
The 7th Issue of the SAR Activity Review contains a list of the categories of suspicious activity, the federal statutes involved and an explanation/ description of each. That's where my inserts came from. Using the documentís page numbers (not those of the PDF file) see page 40.

SAR Activity Review, #7
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#373707 - 06/22/05 02:05 PM Re: SAR - False Statement ?
LoisLane Offline
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LoisLane
Joined: Oct 2001
Posts: 1,570
Wisteria Lane..
Ken, thanks again - - I just found it in your answer to another poster this morning. I think this will help me organize training material for loan officers.
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#373708 - 06/22/05 02:12 PM Re: SAR - False Statement ?
Anonymous
Unregistered

If a SAR has a $5k min threshold, how could a filing be applicable to the submission of an application (that takes place before a monetary transaction )?

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#373709 - 06/22/05 02:27 PM Re: SAR - False Statement ?
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
If they asked for a certain amount of money, that would be the amount of the fraud attempt.
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#373710 - 06/22/05 03:16 PM Re: SAR - False Statement ?
Anonymous
Unregistered

How about if the application was to open a new deposit account with an initial deposit of $10?

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#373711 - 06/22/05 04:11 PM Re: SAR - False Statement ?
GenerousLife Offline
Diamond Poster
Joined: Feb 2002
Posts: 1,466
USA
Quote from FinCEN at the ABA RCC "Go back to your thresholds."
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