The Nephew, the Roof Invoice, and a $14,500 Cashier's Check
At 3:40 p.m. on a Tuesday, member Edith Carver, 81, arrives at the teller line with a younger man she introduces as her nephew Ray. She asks for a $14,500 cashier's check payable to 'R. Sellers' for roof work and to raise her daily debit card limit. Her account holds $16,200, mostly pension income plus a $40,000 certificate that matured and was deposited two weeks ago. The teller notices Edith is unsure of the date and lets Ray answer every question; Ray shows a smartphone photo of a contractor invoice with no license number and a P.O. box address. Two weeks ago she sent a $9,000 wire to a different name that staff flagged as unusual, and a file note says a grandson called about a romance contact. No power of attorney is on file. The branch manager is at lunch, and a teller with four months of experience asks you what to do.
1. What should happen at the window in the next fifteen minutes, and on what authority?
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Slow the transaction down without accusing anyone. Take Edith to a private area away from Ray, and ask her directly, in her own words, what the work is, who Sellers is, and whether she has met him. If she cannot explain, the credit union can decline to issue the check today; there is no duty to complete a withdrawal, and a delay of a few hours is defensible. Do not raise the debit limit. Call the manager and the BSA officer immediately rather than waiting for the lunch hour to end. Under most state elder financial exploitation statutes, financial institutions are authorized, and in many states required, to hold or refuse a transaction and to report to Adult Protective Services, usually within 24 to 48 hours; several states also extend civil immunity for good-faith holds. FinCEN guidance treats elder financial exploitation as a reportable suspicious activity. If Edith is firm, understands the risk, and has capacity, document the conversation and process the transaction; autonomy still applies. If she is confused, the hold and the report stand.
2. The $9,000 wire went out two weeks ago and the $14,500 check is stopped. What are the suspicious activity reporting obligations, and what can and cannot be said to the member?
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Both events belong in one SAR narrative rather than two disconnected filings, describing the wire recipient, Ray, Sellers, the invoice, the grandson's prior call, and Edith's apparent confusion, with dates, amounts, and account numbers. The filing threshold is met on either event; a SAR is due within 30 calendar days of initial detection, extendable to 60 days only when no suspect is identified. The new teller's observation is the detection point, so the clock starts today, not at month end. If the activity continues, review at 120 days and file a continuing activity report with a reference to the original. Confidentiality is strict: federal law prohibits telling anyone, including Edith and including Ray, that a SAR was filed or is contemplated, and prohibits describing the report. That restriction does not prevent a candid conversation with Edith about fraud risk, about the wire recall request, or about a voluntary hold, and it does not prevent reporting to Adult Protective Services or cooperating with law enforcement. Note the distinction in the file, because staff commonly confuse a SAR with a disclosure the member is entitled to.
3. Two days later Edith returns alone and demands her money, saying Ray is family and she knows what she is doing. How do you handle the account going forward?
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First confirm what has actually happened to the $9,000 wire: send a recall request through the sending channel to the receiving institution, document the response, and assume recovery is unlikely once funds are withdrawn. Then hold a documented conversation with Edith covering the invoice irregularities, the speed of the requests, and the pattern of two payees in two weeks. If she demonstrates understanding and insists, give her access on terms the credit union can defend: in-branch only, positive identification, no debit limit increase, and a brief cooling-off period for large outgoing transactions, all disclosed to her in writing. What the credit union should not do is quietly leave a permanent block in place with no basis and no notice, or close the account to make the problem someone else's. Offer a trusted contact designation and a referral to Adult Protective Services, and remind her she can add a family member to help. Document capacity observations factually, not diagnostically, and route the file for periodic review so the decision is not one employee's judgment indefinitely.