Payments-risk officer must resolve whether linked accounts should be treated

Situation

A sudden ACH origination from a previously dormant routing put straw-buyer occupancy file in front of payments-risk officer in a mortgage correspondent channel. This Fraud Detection / Credit and Identity Fraud close is linked accounts should be from straw-buyer occupancy file, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

Payments-risk officer in a mortgage correspondent channel must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using straw-buyer occupancy file after a sudden ACH origination from a previously dormant routing.

Hypotheses to test

• Authorize Remove access or reverse the item now; straw-buyer occupancy file already has the discriminator after a sudden ACH origination from a previously dormant routing.
• Keep Temporary compensating control in force until straw-buyer occupancy file is completed after a sudden ACH origination from a previously dormant routing for payments-risk officer.
• Treat straw-buyer occupancy file as Approve a documented exception because both readings appear after a sudden ACH origination from a previously dormant routing.
• Refuse a Fraud Detection close: payments-risk officer does not have the page linked accounts should be turns on in straw-buyer occupancy file.

Analysis required

• Trace funds, counterparties, and reversals in straw-buyer occupancy file through the window opened by a sudden ACH origination from a previously dormant routing.
• Quantify loss if the hold is released before straw-buyer occupancy file is complete.
• Test a one-off dispute against the first edge of a scheme around linked accounts should be.
• For this Fraud Detection Credit and Identity Fraud file, read straw-buyer occupancy file against a sudden ACH origination from a previously dormant routing and write the one fact that would move linked accounts should be for payments-risk officer.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fraud Detection / Credit and Identity Fraud packet (straw-buyer occupancy file after a sudden ACH origination from a previously dormant routing). The follow-on Credit and Identity Fraud action is what payments-risk officer does next: implement the option, assign an owner, and log the missing fact.