Notice & Comment

Criminal Process: FinCEN Releases Identity Theft Study, by Jonathan Rusch

On October 18, the Financial Crimes Enforcement Network (FinCEN) announced the release of a new study analyzing Suspicious Activity Reports (SARs) citing identity theft. According to FnCen, the study “shows while suspected cases of identity theft are on the rise, vigilant financial institution employees are reportedly rejecting over half of fraudulent vehicle or student loans facilitated by identity theft prior to funding.” The report shows that the number of SARs characterized as identity theft increased 123 percent between 2004 and 2009 — a substantially greater rate of increase than the rise of total SARs filed by depository institutions (89 percent during the same five years).

This post was originally published on the legacy ABA Section of Administrative Law and Regulatory Practice Notice and Comment blog, which merged with the Yale Journal on Regulation Notice and Comment blog in 2015.