If I understand, these are cases in which your customers received unemployment insurance funds that were payable to someone else, and you named the person the funds were payable to a subject.
I don't know that I agree with the statement that you should have investigated further to determine if the payee was a victim of ID theft, but I also understand that in most of these incidents that's the case. I do think I agree with the examiner questioning why those people would be named as subjects, and what role you believe they played in the fraud. The criticism likely boils down to naming someone as a subject in a SAR and not explaining why they're a subject in the narrative. If you did clearly state why you're suspicious of the payees, then I don't know.