Assess whether a provider should be suspended pending SIU (fbd96f)

Situation

Straw-buyer occupancy file arrived with three applications sharing one employer EIN and no payroll for card-issuing fraud analyst. That is a Fraud Detection Mortgage Fraud decision on a provider should be in a mortgage correspondent channel.

Decision

Card-issuing fraud analyst 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 three applications sharing one employer EIN and no payroll.

Hypotheses to test

• Card-issuing fraud analyst can defend Remove access or reverse the item from straw-buyer occupancy file after three applications sharing one employer EIN and no payroll in a Fraud Detection challenge.
• Card-issuing fraud analyst cannot defend Remove access or reverse the item from straw-buyer occupancy file; Temporary compensating control is what the extract actually supports after three applications sharing one employer EIN and no payroll.
• Three applications sharing one employer EIN and no payroll never reached the population in straw-buyer occupancy file — reopen intake, do not close a provider should be.
• Two facts in straw-buyer occupancy file after three applications sharing one employer EIN and no payroll conflict for card-issuing fraud analyst; hold this Mortgage Fraud file.

Analysis required

• Map typology and hold authority card-issuing fraud analyst actually has in a mortgage correspondent channel.
• Trace funds, counterparties, and reversals in straw-buyer occupancy file through the window opened by three applications sharing one employer EIN and no payroll.
• Quantify loss if the hold is released before straw-buyer occupancy file is complete.
• For this Fraud Detection Mortgage Fraud file, read straw-buyer occupancy file against three applications sharing one employer EIN and no payroll and write the one fact that would move a provider should be for card-issuing fraud analyst.

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 three applications sharing one employer EIN and no payroll). If straw-buyer occupancy file cannot force a Fraud Detection label under Mortgage Fraud, stop. Do not invent pages a mortgage correspondent channel does not have.