Question & Answer

Question: What should we give as a reason when placing a hold on a check because we suspect kiting?

Answer: Clearly you don't want to tell the customer what you suspect is going on. You also should file an SAR and not let the customer know that. It is best to say something like "confidential information" and hope that buys enough time to prove or stop the kiting scheme.

Copyright © 1998 Compliance Action. Originally appeared in Compliance Action, Vol. 3, No. 9, 7/98