Identity Theft Prevention Program Red Flag Rule
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1 DIVISION OF FINANCE Committed to Service Excellence Identity Theft Prevention Program Red Flag Rule Texas A&M University and Texas Galveston CSBA Workshop May 21, 2009 Presented by Stacie Sodolak
2 Topics to be covered Purpose Definitions Identification of Red Flags Detection of Red Flags Prevention and Mitigation Response to Red Flags Non-Disclosure Responsibilities 2
3 Purpose 3 The Identity Theft Prevention Program is designed to detect, prevent, and mitigate identity theft in connection with the opening of a covered account or an existing covered account. The University staff responsible for implementing the program shall be trained in the detection of red flags and the responsive steps to be taken when a red flag is detected.
4 Definitions Identity Theft- fraud committed or attempted using the identifying information of another person without authority. Red Flag- pattern, practice, or specific activity that indicates the possible existence of identity theft. 4
5 Definitions Covered Account- consumer account designed to permit multiple payments or transactions, and any other account for which there is foreseeable risk from identity theft. Identifying information- any name or number that may be used, alone or in conjunction with any other information, to identify a specific person. 5
6 Identification of Red Flags Notification and warnings from Credit Reporting Agencies Suspicious Documents Suspicious Personal Identifying Information Suspicious Covered Account Activity or Unusual Use of Account Alerts from Others 6
7 Detection of Red Flags Existing Accounts Verify Identification Validate Requests New Accounts Customer Information Form Verify Identification DO YOU NEED TO EXTEND CREDIT 7
8 Prevention and Mitigation In the event University personnel detect any identified red flags, such personnel shall take the steps outlined under Preventing and Mitigating Identity Theft in the Identity Theft Prevention Program. 8
9 Response to Red Flags Once potentially fraudulent activity is detected, an employee must act quickly as a rapid appropriate response can protect customers and the University from damages and loss. 9
10 Non-disclosure of Specific Practices For the effectiveness of this identity theft program, knowledge about specific red flag identification, detection, mitigation and prevention practices may need to be limited to the committee who developed this program and to those employees with a need to know them. 10
11 Responsibilities 11 Submit new Extension of Credit Letter Due June 15 th to FMO Much more detailed Require copy of billing and collecting procedures Must be certified each year Collect proper identifying information PRIOR to providing goods/services. Have new customers complete customer information form Verify identity of customer before making changes to account Submit monthly AR reports to FMO Review and re-think how you operate Do you really need to extend credit? Can you take the payment now?
12 May 20, 2009 Approval Recommended Denied John Crawford Assistant VP for Finance & Controller MS 6000 C/O Stacie Sodolak Controller Signature Date Account Number: Account Title: Department Code: The account listed above is requesting the authorization to Extend Credit per System Regulation which states: Authorization for an extension of credit operation is delegated to the CFO of the System component extending credit. Written documentation maintained by the CFO should explain the circumstances allowing for an extension of credit and confirm that the operation meets the constitutional test of being in the best interest of the System component and for the public good of the state of Texas. Payment for the sale of goods and services on credit is expected within thirty (30) days.special circumstances requiring the extension of credit for longer than thirty (30) days must be disclosed. If this circumstance is not known at this time, it must be reported as soon as it is known to so it can be routed to the CFO. The document must also contain the following information: (1) Detailed description of the operation. (2) Explain why you have a need to extend credit; include detailed description of efficiencies created by extending credit. (3) Detailed description of administrative cost savings and/or benefits of extending credit that exceed the cost of the operation. 12
13 (4) If receivables will not be reported in FAMIS monthly, you will need to provide a monthly report of receivable billings and collections, including an aging of outstanding accounts receivables balances and a reconciliation of individual account balances to the controlling general ledger balance. This is due by the 25th of each month. (5) Details of your policy to ensure that consitent standards are applied to all applicants requesting an extension of credit. Should include checking previous payment history and/or customers financial capacity to repay debt. (6) Estimation of the duration of the operation, i.e. 6 months, 3 years, ongoing. (7) Estimated value of the extension of credit operation (monthly and aggregate); AND Average amount per invoice. Monthly $ Aggregate $ Amount per Invoice $ (8) Amount of Anticipated annual write-offs. Collection Procedures must be provided. (9) Additional Comments (Include special circumstances here) (10) Customers: Check all that apply. Outside Customers Student Organizations (SOFC) TAMU System Members OTHER I confirm that I have read and understand TAMU System and University regulation regarding Extension of Credit located at I confirm that I have read and understand TAMU's Identity Theft Prevention Program (If you need a copy, please contact AR@tamu.edu) I confirm that my department has written procedures for Extending Credit including collection procedures and all employees involved with this operation are familiar with the procedures and the above listed regulation and program. 13 Attached is a copy of our procedures.
14 Texas A&M University Customer Information Sheet Customer Name: (First name, middle initial, last name) Social Security Number of Federal ID Number TAMU Customer Number (if assigned) Customer Information: Persons authorized to make purchases on this account: Address: City: State: Zip: Contact Name: Title: Accounts Payable Contact Name: Address: Address: Phone: ( ) Fax: ( ) Phone: ( ) Fax: ( ) Name: Customer Representative Title: Signature: Date: This form must be completed in order to extend credit and allow our customers to pay for goods/services at a later date. PAST DUE INVOICES ARE SUBJECT TO BEING REPORTED TO THE STATE COMPTROLLER AND/OR A COLLECTION AGENCY. A FEE WILL BE APPLIED TO ALL RETURNED CHECKS. Privacy Notice: State Law requires that you be informed of the following: (1) You are entitled to request to be informed about the information about yourself collected by use of this form (with a few exceptions as provide by law); (2) you are entitled to receive and review that information; and (3) you are entitled to have the information corrected at no charge to you. TAMU Departmental Certification: Fax completed form to: (979) I have verified the identification of the customer requesting this service. 14 Department Rep Signature:
15 Contacts AR account questions Stacie Sodolak Student account questions Bob Piwonka 15
16 Resources Red Flags Rule (16 C.F.R ) Appendix A to Red Flags Rule (Appendix A to Part 681) Red Flags Rule (final rule as published in the Federal Register) FTC Enforcement Policy on Red Flags Rule A&M System Regulation , Extension of Credit, Extension of Credit Letter Request Form 16
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