Seeing like a Bank
www.bitsaboutmoney.com/archive/seeing-like-a-bank/
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To beat a drum
Why does it happen across issues as diverse as bank-initiated account closures, credit card or Zelle fraud, debit card reissuance, and mortgage foreclosures? Why does it happen in such a similar fashion across many institutions, of all sizes, who exist in vicious competition with each other and who know their customers hate this? Banks are extremely good at tracking one kind of truth, ledgers. They are extremely bad at tracking certain other forms of truth, for structural reasons.
Sometimes banks suck because we want them to suck. In the specific case of “Why did the bank close my account, seemingly for no reason? Why will no one tell me anything about this? Why will no one take responsibility?”, the answer is frequently that the bank is following the law. As we’ve discussed previously, banks will frequently make the “independent” “commercial decision” to “exit the relationship” with a particular customer after that customer has had multiple Suspicious Activity Reports filed. SARs can (and sometimes must!) be filed for innocuous reasons and do not necessarily imply any sort of wrongdoing. SARs are secret, by regulation. See 12 CFR § 21.11(k)(1) from the Office of Comptroller of the Currency:
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