What is the Bank's due dilligence requirement if we pull a credit bureau, notice there is an alert and end up denying the credit for some other reason such as loan to value? Is there a due dilligence requirement to follow up on the alert?

One thing is that if you believed the individual applying for credit was an imposter, you would need to file a SAR.

If there is an alert and within that alert there are instructions on how to contact the consumer that placed the alert, you need to do that. That consumer that placed the alert can come to you for copies of the application, etc. You need procedures in place on how to handle that request, per the FACT Act.

If this is an existing customer you should also have a procedure in place to denote the flag/alert at a CIF level. Say you denied the loan for a non-associated reason and then get a request for a replacement debit card and address change. How can the department that handles that request know that an alert exists and process the request only after verifying the change is from your real customer?

Once you have knowledge of a fraud alert, you must not proceed until you have verified the identity of the applicant.

To continue this post (I searched first),, In the case where we have a positiveID but the alert is related to a mis-matched address are banks clearing the address issue before they send out the denial??