Assess whether a SAR narrative is supportable today (f52e12)

Situation

A SAR narrative is sits with account-opening quality reviewer because a sudden ACH origination from a previously dormant routing hit an ACH originating credit union. Evidence is mule-account payroll deposit pattern; write the Fraud Detection Mortgage Fraud option that extract can carry.

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 mule-account payroll deposit pattern after a sudden ACH origination from a previously dormant routing.

Hypotheses to test

• A sudden ACH origination from a previously dormant routing is noise around an already-controlled Mortgage Fraud process in an ACH originating credit union, given mule-account payroll deposit pattern.
• A sudden ACH origination from a previously dormant routing is the event in mule-account payroll deposit pattern that forces Remove access or reverse the item for account-opening quality reviewer under Fraud Detection.
• Mule-account payroll deposit pattern shows a one-file miss after a sudden ACH origination from a previously dormant routing, not a Mortgage Fraud program failure.
• Mule-account payroll deposit pattern cannot decide a SAR narrative is yet after a sudden ACH origination from a previously dormant routing; hold is the only Fraud Detection close an ACH originating credit union can defend.

Analysis required

• Map typology and hold authority account-opening quality reviewer actually has in an ACH originating credit union.
• Trace funds, counterparties, and reversals in mule-account payroll deposit pattern through the window opened by a sudden ACH origination from a previously dormant routing.
• Quantify loss if the hold is released before mule-account payroll deposit pattern is complete.
• For this Fraud Detection Mortgage Fraud file, read mule-account payroll deposit pattern against a sudden ACH origination from a previously dormant routing 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 (mule-account payroll deposit pattern after a sudden ACH origination from a previously dormant routing). Lead with the Fraud Detection option mule-account payroll deposit pattern can support after a sudden ACH origination from a previously dormant routing, then the two facts that force it, then the Monday action for account-opening quality reviewer in an ACH originating credit union.