Assess whether a provider should be suspended pending SIU (3a5869)

Situation

The desk packet is straw-buyer occupancy file after a 400% utilization jump in 11 days. Payments-risk officer in an ACH originating credit union has to name Remove access or reverse the item or Temporary compensating control for this Fraud Detection Payments Fraud file.

Decision

Payments-risk officer 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 400% utilization jump in 11 days.

Hypotheses to test

• The population in straw-buyer occupancy file is the one a 400% utilization jump in 11 days named, so Remove access or reverse the item follows for this Payments Fraud file.
• The population in straw-buyer occupancy file is adjacent only to a 400% utilization jump in 11 days; Temporary compensating control is the honest Fraud Detection call.
• An ACH originating credit union already contained a 400% utilization jump in 11 days before straw-buyer occupancy file arrived; no new Payments Fraud path.
• Provenance on straw-buyer occupancy file after a 400% utilization jump in 11 days is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Check mule or round-trip markers in straw-buyer occupancy file.
• Map typology and hold authority payments-risk officer actually has in an ACH originating credit union.
• Trace funds, counterparties, and reversals in straw-buyer occupancy file through the window opened by a 400% utilization jump in 11 days.
• For this Fraud Detection Payments Fraud file, read straw-buyer occupancy file against a 400% utilization jump in 11 days and write the one fact that would move a provider 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 / Payments Fraud packet (straw-buyer occupancy file after a 400% utilization jump in 11 days). The follow-on Payments Fraud action is what payments-risk officer does next: implement the option, assign an owner, and log the missing fact.