Answer:
It would follow ordinary SAR reporting requirements. You should file a SAR if you have an identified suspect and the loan was more than $5,000 or regardless of suspect if the loan was for more than $25,000. You also have an obligation under the Fair Credit Reporting Act to provide information about the fraudulent account to the law enforcement agency of the identity theft victimized individual, once you have established the true identity of that individual. At least that's the way I think I heard Mary Beth Guard explain it in her webinar on Subpoenas, Summons, and Search Warrants.
First published on BankersOnline.com 1/15/07
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