All associates, including management, are required to escalate possible suspicious activity to the BSA Compliance Officer, using the Confidential Preliminary Suspicious Incident Referral.  The BSA Compliance Officer will research the suspected activity and take appropriate action, in accordance to the law as well as company policy.

It is impossible to define all activity that could potentially be suspicious.  The below list includes some example that may warrant additional scrutiny.  This list is not intended to be an all-inclusive list.

• Source of funds appears false, misleading, or substantially incorrect;

• Failure to provide legitimate source or funds or other assets;

• Unexplained or sudden extensive activity in bank account statements;

• Multiple bank accounts, or maintain accounts in the names of family members or corporate entities with no apparent purpose;

• Unexplained business activities; Difficulty describing nature of business and/or the tax transcripts do not support the income verified in the loan file

• Unusual, suspicious, inconsistent identification or documentations

• Discrepancies found when comparing the documentation provided with the credit report

• Inflows of funds or assets exceed known income or resources

• Lack of concerns for transaction costs is exhibited

• Possible “Straw buyer” situation

• Invalid or unverifiable Social Security Number

• Property has been flipped many times.  Current seller is not on title or has owned the property for a short time

• Questionable intent to occupy based on documentation or unrealistic commute

• Discrepancies of borrower/seller’s name found on documents, sales contract, title, etc.

RESPONDING TO SUSPICIOUS ACTIVITY

Please complete and submit a Confidential Preliminary Suspicious Incident Referral  by clicking the "Next Page" link below. Suspicious activity may also be reported by calling (949) 270-7611.