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#984961 - 06/30/08 04:29 PM ITPP Red Flag - App appears altered or forged
Many Hats Offline
Platinum Poster
Joined: May 2008
Posts: 915
Orlando, FL
As a potential response to the red flag "An application appears to have been altered or forged, or gives the appearance of having been destroyed and reassembled," it has been suggested that we respond by sending the applicant an adverse action notice indicating that "Credit application is incomplete. The following information is needed: original signed application submitted to branch office."

This is assuming that the application was received by mail. By sending this notice, the person applying for credit will be prompted to come into a branch in person to submit the application, then the information can be verified at that time. Or, if the person at that address did not apply for credit, the letter would prompt them to contact us.

Does this sound like an acceptable way to respond?

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#984976 - 06/30/08 04:47 PM Re: ITPP Red Flag - App appears altered or forged Many Hats
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,423
Bloomington, IN
If that's how you want to respond then that would be appropriate. To the best of my knowledge there are no "set ways" to respond.

The response section is to be completed with the steps you will take to prevent/mitigate identify theft when a red flag is identified. It may be a response as you noted above or it may "cross reference" a CIP and/or IT procedure.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#985126 - 06/30/08 06:25 PM Re: ITPP Red Flag - App appears altered or forged Many Hats
Jack Holzknecht Offline

Gold Star
Joined: Aug 2001
Posts: 330
Louisville, KY
Stating that the application is incomplete and requesting a signed original application, may create problems under regulation B. The customer has already submitted a signed original application.

I suggest a more straight forward approach. State that while the application was complete, it appears to have been altered or forged, or gives the appearance of having been destroyed and reassembled. Then in order to complete the application process the borrower must appear at a branch with appropriate ID to complete a new application or to have their identity verified.

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