Out-of-band wire verification runs the verification framework against a separate communication channel from the channel that delivered the wire instruction. This article walks the five-step framework against each wire verification on the lender’s framework.

Step 1: Identify the channel of the wire instruction

The lender runs the channel-identification framework against the wire instruction. The wire instruction runs through email, the loan-management system, a closing-portal framework, a borrower-portal framework, or a direct-call framework. The lender runs the verification framework against a separate channel from the channel that delivered the wire instruction on the standard.

Step 2: Find the pre-existing record

The lender runs the pre-existing record framework against the counterparty. The pre-existing record runs the borrower’s loan-application phone number, the vendor’s W-9 phone number, the title-company’s closing-instructions phone number, or the counterparty’s contract phone number on the standard. The lender runs the verification framework against the pre-existing record framework — never against a phone number on the incoming wire instruction or against a phone number in an email signature.

Step 3: Run the callback

The lender runs the callback framework against the pre-existing record on the phone framework. The callback framework runs the verification against the wire amount, the recipient bank name, the recipient routing number, the recipient account number, the recipient name on the account, and the wire-instruction reference on the loan or transaction. The callback framework runs the verification against a human counterparty on the standard — voicemail framework runs the callback framework on a non-completed framework against the verification.

Step 4: Document the verification

The lender runs the documentation framework against the wire-verification cycle. The framework runs against three elements — the date and time of the verification call, the phone number called and the source of the phone number (pre-existing record framework), and the verification of the wire-instruction details against the counterparty on the call. The lender runs the documentation framework against the wire-file or loan-file framework on the audit-trail framework.

Step 5: Run dual control on the wire approval

The lender runs the dual-control framework against the wire-approval discipline. The wire-initiation framework runs against one role on the framework. The wire-approval framework runs against a separate role on the framework. The framework runs the second-set-of-eyes discipline against the wire amount, the recipient framework, the wire-instruction reference, and the verification-documentation framework on each wire. The dual-control framework runs the wire-approval discipline against the lender’s wire-fraud framework.

Related Topics

• Five Wire Fraud Defenses for Private Lenders
• Fidelity Bonds for Trust Account Signatories
• Quarterly Waterfall Distributions for Mortgage Funds
• Mortgage Fund Subservicing Done Right
• Multi-Lender Notes With Up to 10 Investors

This article is educational and does not constitute legal, financial, or cybersecurity advice. The wire-fraud defense framework runs against the lender’s operational discipline, the lender’s insurance framework, and the FBI Internet Crime Complaint Center framework on the ic3.gov framework. Consult qualified legal counsel, an insurance broker, and a cybersecurity adviser on the specific wire-fraud framework against any private-lending operation.

Sources

• FBI Internet Crime Complaint Center — ic3.gov. Federal Bureau of Investigation.
• FBI Domestic Financial Fraud Kill Chain. Federal Bureau of Investigation.
• FinCEN — Financial Crimes Enforcement Network advisories on business-email compromise. Financial Crimes Enforcement Network.
• FFIEC IT Examination Handbook — Wholesale Payment Systems. Federal Financial Institutions Examination Council.
• CISA — Cybersecurity and Infrastructure Security Agency advisories on business-email compromise. Cybersecurity and Infrastructure Security Agency.