Assess whether to refer to law enforcement or keep civil (fd797e)

SITUATION First-party friendly-fraud dispute pack arrived with three applications sharing one employer EIN and no payroll for bank BSA/AML case manager. That is a Fraud Detection Mortgage Fraud decision on to refer to law in a regional bank's card portfolio.

DECISION Bank BSA/AML case manager in a regional bank's card portfolio must choose To refer to law enforcement / Keep civil using first-party friendly-fraud dispute pack after three applications sharing one employer EIN and no payroll.

HYPOTHESES TO TEST 1. Authorize To refer to law enforcement now; first-party friendly-fraud dispute pack already has the discriminator after three applications sharing one employer EIN and no payroll. 2. Keep Keep civil in force until first-party friendly-fraud dispute pack is completed after three applications sharing one employer EIN and no payroll for bank BSA/AML case manager. 3. Treat first-party friendly-fraud dispute pack as To refer to law enforcement because both readings appear after three applications sharing one employer EIN and no payroll. 4. Refuse a Fraud Detection close: bank BSA/AML case manager does not have the decision to refer to law turns on in first-party friendly-fraud dispute pack.

ANALYSIS REQUIRED 1. Map typology and hold authority bank BSA/AML case manager actually has in a regional bank's card portfolio. 2. Trace funds, counterparties, and reversals in first-party friendly-fraud dispute pack through the window opened by three applications sharing one employer EIN and no payroll. 3. Quantify loss if the hold is released before first-party friendly-fraud dispute pack is complete. 4. For this Fraud Detection Mortgage Fraud file, read first-party friendly-fraud dispute pack against three applications sharing one employer EIN and no payroll and write the one fact that would move to refer to law for bank BSA/AML case manager.

RECOMMENDATION Choose To refer to law enforcement / Keep civil on this Fraud Detection / Mortgage Fraud packet (first-party friendly-fraud dispute pack after three applications sharing one employer EIN and no payroll). 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.

COMMAND RETURNS - Bottom-line Fraud Detection option on to refer to law, then the evidence in first-party friendly-fraud dispute pack, then the action for bank BSA/AML case manager - Hypothesis scorecard against first-party friendly-fraud dispute pack: supported / rejected / untestable - Regulatory or exam hook Mortgage Fraud would cite - Mortgage Fraud finding in first-party friendly-fraud dispute pack that a second reviewer can re-perform