Assess whether linked accounts should be treated as one case (badb96)

Situation

Mortgage Fraud work in an ACH originating credit union now turns on linked accounts should be because a title company wiring to a last-minute account put straw-buyer occupancy file in play. Account-opening quality reviewer should say what straw-buyer occupancy file proves.

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 straw-buyer occupancy file after a title company wiring to a last-minute account.

Hypotheses to test

• A title company wiring to a last-minute account is noise around an already-controlled Mortgage Fraud process in an ACH originating credit union, given straw-buyer occupancy file.
• A title company wiring to a last-minute account is the event in straw-buyer occupancy file that forces Remove access or reverse the item for account-opening quality reviewer under Fraud Detection.
• Straw-buyer occupancy file shows a one-file miss after a title company wiring to a last-minute account, not a Mortgage Fraud program failure.
• Straw-buyer occupancy file cannot decide linked accounts should be yet after a title company wiring to a last-minute account; hold is the only Fraud Detection close an ACH originating credit union can defend.

Analysis required

• 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.
• Check mule or round-trip markers in straw-buyer occupancy file.
• For this Fraud Detection Mortgage Fraud file, read straw-buyer occupancy file against a title company wiring to a last-minute account and write the one fact that would move linked accounts should be 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 (straw-buyer occupancy file after a title company wiring to a last-minute account). 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.