Our procedures say that if a Fraud Alert is on a credit bureau we will use the contact method listed and our current CIP procedures to positively identify the customer. We do not address what actions to take if the customer cannot be positively identified other than not proceeding with opening the account.

What other steps should we be taking? Allowing the customer to return with positive ID? At what point should we notify law enforcement, file an SAR, if at all?

Has anyone else had these questions asked?

Thanks