Assess whether a payment hold survives a customer complaint (f36bb5)

Situation

Mule-account payroll deposit pattern arrived with a sudden ACH origination from a previously dormant routing for bank BSA/AML case manager. That is a Fraud Detection Mortgage Fraud decision on a payment hold survives in a regional bank's card portfolio.

Decision

Bank BSA/AML case manager in a regional bank's card portfolio 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

• The population in mule-account payroll deposit pattern is the one a sudden ACH origination from a previously dormant routing named, so Remove access or reverse the item follows for this Mortgage Fraud file.
• The population in mule-account payroll deposit pattern is adjacent only to a sudden ACH origination from a previously dormant routing; Temporary compensating control is the honest Fraud Detection call.
• A regional bank's card portfolio already contained a sudden ACH origination from a previously dormant routing before mule-account payroll deposit pattern arrived; no new Mortgage Fraud path.
• Provenance on mule-account payroll deposit pattern after a sudden ACH origination from a previously dormant routing is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Quantify loss if the hold is released before mule-account payroll deposit pattern is complete.
• Test a one-off dispute against the first edge of a scheme around a payment hold survives.
• Check mule or round-trip markers in mule-account payroll deposit pattern.
• 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 payment hold survives for bank BSA/AML case manager.

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). The follow-on Mortgage Fraud action is what bank BSA/AML case manager does next: implement the option, assign an owner, and log the missing fact.