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Wire fraud reaches a closing file through a familiar path. A borrower receives an email that looks like it came from the title company, the message includes new account details, and the closing team forwards the change without a callback. A two-person check adds a second set of eyes without turning every closing into a lengthy review. The key is to separate the preparation from the confirmation and to use a contact path the team already trusts.
Where wire fraud enters the closing file
The risky moment is rarely the first set of instructions. It is the change that arrives close to closing, when everyone is watching the calendar and the borrower is anxious to finish. A message that asks for a new account or a same-day transfer should trigger a pause even when it looks routine. The team should treat urgency as a reason to verify, not a reason to skip verification.
Another entry point is an internal forward. A processor may receive correct instructions from a known title officer, then forward them through a personal inbox where the thread can be altered. The file should keep the original source and the confirmation together. A clean copy without the surrounding context is harder to defend when a dispute arises later.
Split verification into prepare and confirm
Give one person the job of preparing the wire packet. That person confirms the payee, the amount, the account details, and the closing date against the approved file. Give a second person the job of confirming the packet through an independent channel. The preparer can be a specialist, while the confirmer should be someone with authority to stop the closing if something does not match.
The two roles should not share the same source for the callback number. If both people read the number from the suspicious email, the check proves only that they can read the same message. The confirmer should use a number from the title company's known contact record, a prior signed document, or a directory the team maintains. Independence is what makes the second look meaningful.
Use a callback number from an independent source
Write the approved callback procedure into the closing checklist. The confirmer calls the title company, states the file reference, and asks the recipient to read back the account details. The confirmer should not read the details first and ask for a yes or no, because that turns the call into a confirmation of whatever was already written. Let the other side supply the information, then compare it to the packet.
Record the name of the person reached, the number dialed, the time, and the result. If the call goes to voicemail, the check is not complete. A callback that cannot reach a person should hold the wire until a verified contact is available. The closing coordination workflow should make that hold an approved outcome rather than an exception that requires a manager to rescue.
Record the check before releasing the file
The wire packet should not move to the closing table until the confirmation is recorded. Add a field for the preparer, the confirmer, the callback time, and the source of the number used. Keep the record with the closing documents rather than in a chat thread. A later reviewer should be able to reconstruct the check without interviewing the people involved.
The record also needs a place for the discrepancy, if one exists. A wrong digit in an account number is easier to resolve when the team can see which source supplied the number and who confirmed it. Do not overwrite the earlier instructions when a new set arrives. Keep both versions and mark which one was verified.
Keep the check fast on routine files
A two-person check can sound like a second closing. In practice, a routine file with stable instructions can clear in a few minutes when the roles and the callback list are ready. The preparer completes the packet before the closing appointment, and the confirmer makes one call at a scheduled time. The delay comes from missing information, not from the second person.
Build the check into the closing calendar rather than adding it at the last minute. Schedule the confirmation for the morning of the closing or the afternoon before, depending on the title company's practice. The CFPB's closing disclosure guidance explains the timing borrowers expect, and the internal wire check should fit inside that window. A planned call is faster than an emergency one.
Test the control with a simulated change
Once a quarter, run a tabletop exercise with a changed account request. Give the team a fake message with a plausible new number and see whether the preparer and confirmer follow the procedure. Do not tell the confirmer which details changed. The exercise tests whether the callback actually reaches an independent source and whether the team can stop the file without blaming anyone.
Review the exercise and update the callback list and the checklist. If the team skipped the call because the closing was close, fix the schedule rather than writing a stronger warning. A control that depends on heroics will fail on the day the hero is on leave. The loan processing support team can own the routine preparation while the closing owner keeps the approval.
Make the stop decision easy to defend
The person who stops a wire needs cover from the process, not just personal courage. Write a short rule that says an unverified change holds the closing until the callback is complete. Give the confirmer the authority to pause without asking for permission from someone who is focused on the closing date. The rule should be visible to the borrower-facing team as well.
When a hold happens, tell the borrower what is being checked and when the next update will come. Avoid describing the borrower as the problem or suggesting that the delay is unusual. A calm explanation protects the relationship and reinforces that the team takes the transfer seriously. The same discipline that prevents fraud also makes the closing process easier to trust.