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Bank's Liability For Forged CTR Signatures

Answered by: 
John Burnett

Question: 
We have been advised by an employee that her name has been forged seven times on CTRs. She discovered this when our home office notified her to check a possible error. She looked and did not remember the customer. She discovered her name on the document and it was not her signature. She looked through the log and found six others where her name was forged. What is the bank's liability? What should we do?
Answer: 

First, make certain that the CTRs were accurate, complete and timely. If they were not, the person whose name appears on the CTR might have a legitimate concern, since she could be held accountable. Document to your and her satisfaction that she did not, in fact, complete or sign the forms.

Then comes the hard part. Determine how her name was put on the forms. Investigate others who worked in that office on the dates in question. Signing someone else's name without authority is a serious matter, and if you determine who did it, it's grounds for dismissal, in my opinion.

First published on BankersOnline.com 04/07/03

First published on 04/07/2003

Filed under: 
Compliance
Filed under compliance as: 
Employee
IT

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