Assess whether a SAR narrative is supportable today (190e2f)

Situation

A mule account receiving 14 unrelated payrolls in a week put bust-out credit-line utilization curve in front of account-opening quality reviewer in an ACH originating credit union. This Fraud Detection / Mortgage Fraud close is a SAR narrative is from bust-out credit-line utilization curve, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

Account-opening quality reviewer in an ACH originating credit union must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using bust-out credit-line utilization curve after a mule account receiving 14 unrelated payrolls in a week.

Hypotheses to test

• Authorize Remove access or reverse the item now; bust-out credit-line utilization curve already has the discriminator after a mule account receiving 14 unrelated payrolls in a week.
• Keep Temporary compensating control in force until bust-out credit-line utilization curve is completed after a mule account receiving 14 unrelated payrolls in a week for account-opening quality reviewer.
• Treat bust-out credit-line utilization curve as Approve a documented exception because both readings appear after a mule account receiving 14 unrelated payrolls in a week.
• Refuse a Fraud Detection close: account-opening quality reviewer does not have the page a SAR narrative is turns on in bust-out credit-line utilization curve.

Analysis required

• Trace funds, counterparties, and reversals in bust-out credit-line utilization curve through the window opened by a mule account receiving 14 unrelated payrolls in a week.
• Quantify loss if the hold is released before bust-out credit-line utilization curve is complete.
• Test a one-off dispute against the first edge of a scheme around a SAR narrative is.
• For this Fraud Detection Mortgage Fraud file, read bust-out credit-line utilization curve against a mule account receiving 14 unrelated payrolls in a week and write the one fact that would move a SAR narrative is for account-opening quality reviewer.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fraud Detection / Mortgage Fraud packet (bust-out credit-line utilization curve after a mule account receiving 14 unrelated payrolls in a week). The follow-on Mortgage Fraud action is what account-opening quality reviewer does next: implement the option, assign an owner, and log the missing fact.