Product: Checking or savings account

XX/XX/XXXX Re : Fraud at our Truist Business Checking Account To Whom This May Concern : In the last 10 months, our business checking account, XXXX XXXX XXXX XXXX, has had fraudulent activity over 20 times. As many as 6 instances were washed checks caught by the fraud department in XXXX of XXXX, and the deposited checks were returned the next day. Of those attempts, we were not notified in every case. These deposited checks did not show up in our printed statement, however once we were aware of these attempts we were able to see the images online. We had no idea that they even existed until our CPA got involved this week. 
Of these approximately 20 attempts only five have a claim number that we are aware of. Yesterday, we found more fraudulent activity in XXXX, notified Truist and attached those to the last claim number yesterday. 
This happened again two weeks ago when we found a fraudulent check for {$35000.00}. This check was to the same individual that was caught in XXXX in the amount of {$9800.00}. They replaced the {$9800.00} in our account after a two week investigation. This check was clearly not ours and the signature was not on our signatory card ( this is true in every case ) We contacted our CPA to do a complete reconciliation of account for this year. We do monitor the account, but do not officially reconcile but once or twice a year. Once the CPA was complete, we realized since XX/XX/XXXX there is a loss of over {$100000.00} due to fraudulent activity ( not accounting for the aforementioned checks Truist pulled, and the {$9800.00} that Truist has reimbursed us for. 
We called yesterday to speak with the bank. The fraud department said they really can only go back thirty days with any claims for reimbursement. When we explained we don't even receive a statement until the middle of the month, they replied that since statements were available online. The date we receive the statement is around the first of the month. They " graciously '' requested reimbursement to their claim department to go back to XX/XX/XXXX, but the biggest fraudulent transaction was a bank to bank transfer of {$48000.00} in XXXX, XXXX and was not something they could help with. XXXX is the same month that the bank identified six checks that were fraud, but only alerted us to two of them. 
Our biggest concern is that through this all Truist never suggested closing the bank account number, even though they had thwarted six checks in one month ( XXXX, the same month with the $ XXXX theft ). Truist never suggested or offered any other ways for us to protect the account, and they never suggested we contact the police. On the advice of our CPA, we have now contacted the XXXX police and they have initiated an investigation. The first claim happened in XX/XX/XXXX for approximately {$6200.00}. The next washed check occurred in XX/XX/XXXX. 
We believe that due to the constant and repeated fraudulent activity that Truist did not do enough to protect us from fraud, and did not follow protocols to help us : 1 ) Never suggested to close the account 2 ) Only mentioned their Positive Pay program yesterday XX/XX/XXXX after we got a rude phone call wanting to know if we still wanted payroll to go through since the account was negative. 
3 ) Did not notify us of the four of the six checks they returned, and we could not see the checks in the printed bank statement. The only images were online, although they are listed on the statements as cashed checks, with a matching deposit the next day. 
We expect Truist to reimburse all losses back to XX/XX/XXXX. They say it is not within their power to do so and our only hope is that the Police do it for us. 
While we have filed a report with the local police department, we believe that Truist did not follow proper protocol and is in violation of the BSA/AML. Specifically, but not inclusively, in violation of Part 353 Suspicious Activity Reports Section 353.3 Reports and Records ( a ) ( 2 ), ( 3 ) and ( 4 ). Without reporting to local authorities, we believe they are also in violation of subset ( c ) of the same Part stated above. 
We believe that Truist also has a UDAAP violation, by not closing our account with repeated attempts at fraud, and not advising us on steps to avoid the repeated fraudulent activity, and not advising us to report to authorities. 
By continuing to keep the account open, without an elevated amount of scrutiny based on the fraud discoveries, we believe they are in violation of Regulation P, by allowing banking information to be repeatedly used for fraudulent checks, instead of changing the account so our bank account information could not be continued to be manipulated. 
Our knowledge on this subject is limited, and therefore, there may be other regulations Truist is in violation that we are ignorant of. We ask your help to identify those that we may not have identified. 




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