The FACT Act An Overview
|
|
- Giles Blair
- 6 years ago
- Views:
Transcription
1 The FACT Act An Overview The FACT Act An Overview of the Final Rulemaking on Identity Theft Red Flags and Address Discrepancies Naomi Lefkovitz Attorney, Division of fprivacy and didentity Protection Federal Trade Commission 1
2 Call Logistics - All lines muted - Use Chat Feature for questions - Recording link will be ed later in week. 2
3 Schools on the call today: Bryant University College of Mount St. Joseph Howard Community College Indiana State University Lake Forest Graduate School of Management Purdue University San Francisco State University Southeastern Louisiana University University of Texas at Brownsville Youngstown State University 3
4 Statutory Provisions Implemented The Fair and Accurate Credit Transactions Act of 2003 (FACT Act) amended d the Fair Credit Reporting Act (FCRA) Sections 114 and 315 of the FACT Act Rules: 72 Fed. Reg (November 9, 2007) 4
5 Background Joint rulemaking Final rules published November 9, 2007 Compliance required by November 1, 2008, but enforcement forbearance for 16 CFR for entities under FTC jurisdiction 5
6 Identity Theft Red Flags FACT Act Section 114 FCRA Section 615(e) 16 CFR and
7 Identity Theft Red Flags Risk-based final rule Guidelines (Appendix A) Supplement A (26 examples of red flags) 7
8 Purpose of the Red Flags Rule To detect and stop identity thieves using someone else s identifying information at your institution to commit fraud. Distinct from data security 8
9 Covered Entities Financial institutions and creditors must conduct a periodic risk assessment to determine if they have covered accounts. 9
10 Definitions From the FCRA, a financial institution is: A state or national bank A state or federal savings and loan association A mutual savings bank A state t or federal credit union, or Any other person that directly or indirectly holds a transaction account* belonging to a consumer * From the Federal Reserve Act, Sec. 19(b) - an account that allows withdrawals by negotiable or transferable instrument, payment orders of withdrawal, telephone transfers, or similar items to make payments or transfers to 3 rd persons or others. 10
11 Definitions (cont d) From ECOA, a creditor is: Any person who regularly extends, renews, or continues credit Any person who regularly arranges for the extension, renewal, or continuation of credit, or Any assignee of an original i creditor who participates in the decision to extend, renew, or continue credit 11
12 Definitions (cont d) An account is: a continuing relationship established by a person with an FI or creditor to obtain a product or service for personal, household, or business purposes. 12
13 Definitions (cont d) A covered account is: A consumer account designed to permit multiple payments or transactions, and Any other account for which there is a reasonably foreseeable risk from identity theft 13
14 Scenario #1 Rural U. has about 1100 students and is located in a small town surrounded by miles of farmland. Tuition is due before e classes begin, but a few students are permitted to pay on an installment plan. Students can use cash, credit card, or their student photo ID card for various goods and services on the campus such as at the bookstore or the health clinic. For students who use their ID card, the bookstore sends a bill due upon receipt. The health clinic also bills for amounts unpaid by insurance. 14
15 Scenario #2 Metro U. serves about 40,000 students in an urban setting. It has many graduate schools, and is affiliated with a hospital. Students have a variety of loan options, including the Perkins Loan Program. In many cases, loan amounts are applied directly to tuition, but students can also get checks directly for living expenses. Metro U. also provides students with a debit card, Metrobucks, linked to a prepaid declining balance account. Students can use the Metrobucks card on and off campus to purchase food, books, etc. Students also have the option to link the Metrobucks card to a checking account at Big Bank. 15
16 Program Requirement Financial institutions and creditors with covered accounts must implement a written Identity Theft Prevention Program to detect, prevent, and mitigate identity theft in connection with: the opening of a covered account, or any existing covered account 16
17 Program Requirement (con t) The Program must be appropriate to the size and complexity of the financial institution or creditor and the nature and scope of activities. 17
18 Elements of the Program Must include reasonable policies and procedures to: Identify relevant red flags* and incorporate them into the Program Detect red flags that are part of the Program Respond appropriately itl to any red dflags that thtare detected dt td Ensure the Program is updated periodically to address changing risks * A red flag is a pattern, practice, or specific activity that could indicate identity theft 18
19 Administration of the Program Obtain approval of the initial Program by the board or a committee thereof Thereafter may designate a senior management employee to oversee: Development, implementation, and administration of the Program Training of appropriate staff Service provider arrangements 19
20 Consideration of the Guidelines Rules require: Consideration of the Guidelines Incorporation of appropriate Guidelines into the Program 20
21 Identity Theft Red Flag Guidelines 21
22 Overview of the Guidelines I. Incorporate existing policies and procedures II. Identify relevant red flags III. Procedures to detect red flags IV. Appropriate p responses to red flags V. Periodic updating of the Program VI. V. Administering gthe Program oga VII. Other legal requirements 22
23 I. Incorporate Existing Policies and Procedures Existing anti-fraud program Information security program 23
24 II. Identify Relevant Red Flags Risk factors for identifying relevant red flags are: Types of covered accounts offered or maintained Methods provided to open or access covered accounts Previous experiences with identity theft 24
25 II. Identify Relevant Red Flags (cont d) Sources of red flags are: Incidents of identity theft that have been experienced Methods of identity theft reflecting changes in identity theft risks Applicable supervisory guidance 25
26 II. Identify Relevant Red Flags (cont d) Five categories of red flags* are: Alerts, notifications, or other warnings received from consumer reporting agencies or service providers Presentation of suspicious documents Presentation of suspicious personal identifying information Unusual use of, or other suspicious activity related to, a covered account Notice from customers, victims of identity theft, or law enforcement authorities * 26 examples are found in Supplement A 26
27 III. Procedures to Detect Red Flags Verify identity Authenticate customers Monitor transactions Verify validity of address changes 27
28 IV. Appropriate p Responses to Red Flags Monitor accounts Contact customer Change passwords Close and reopen account Refuse to open account Don t collect on or sell account (against the true consumer) Notify law enforcement No response is warranted 28
29 V. Periodic Updating of the Program Experience with identity theft Changes in methods of identity theft Changes in methods to detect, prevent, and mitigate identity theft Changes in types of accounts offered Changes in business arrangements 29
30 VI. Administering the Program Oversight of the Program by the Board or a senior management employee involves: Assigning specific responsibility for implementation Reviewing reports Approving material changes in the Program 30
31 VI. Administering the Program (cont d) Reports to the Board or senior management employee: At least annually Address material matters Service provider arrangements Effectiveness of the policies and procedures in addressing the risk of identity theft in connection with covered accounts Significant incidents involving identity theft and management s response Recommendations for material changes to the Program 31
32 VI. Administering the Program (cont d) Oversight of service providers: Ensure the service provider s activities are conducted in accordance with reasonable policies and procedures designed to detect, prevent, and mitigate tgatethe risk of identity ttytheft et 32
33 VII. Other Legal Requirements Suspicious Activity Reports (SARs) Other FCRA provisions (e.g. 15 U.S.C. 1681s-2, information furnisher duties to update or correct inaccurate information, and not report inaccurate information) 33
34 Examples of Red Flags (Supp. A) Warning from consumer reporting agencies Fraud or active duty alert included in consumer report Suspicious documents Suspicious personal information Documents provided for identification appear to be altered Inconsistent with external information sources 34
35 Examples of Red Flags (cont d) Unusual use of account Account used in a manner that is not consistent with historical patterns of activity i Notice from customers Customer notifies institution about identity theft. 35
36 Enforcement of Red Flags Rules Administrative enforcement under 15 USC Sec. 1681s (Section 621 of the FCRA) No private right of action State Attorneys General No criminal penalties 36
37 Don tpanic! The Programs are risk-based and flexible. Consider the bigger picture. 37
38 Rule on Duties of Card Issuers Regarding gchanges of Address 38
39 Identity Theft Red Flags FACT Act Section 114 FCRA Section 615(e) 16 CFR
40 Covered Entities Financial institutions or creditors that issue debit or credit cards. 40
41 Address Validation A card issuer must have reasonable policies and procedures to assess an address change when: A consumer sends a notice of address change, and The card issuer receives a request for an additional or replacement card within at least the first 30 days after the address change notice. 41
42 Address Validation (con t) Before issuing the additional or replacement card, the card issuer must: Notify* the cardholder of the request and allow a reasonable means to report an incorrect address change, or Otherwise assess the validity of the address change in accordance with its Identity Theft Prevention Program *Notice can be given at the cardholder s former address or by any other communication means agreed upon. 42
43 Alternative Timing The card issuer may fulfill the requirements of this rule when it receives the address change notification, before receiving the request for the additional or replacement card. 43
44 Form of Notice The notice may be written or electronic, but it must be clear and conspicuous* and be provided separately from regular correspondence with the cardholder. *reasonably understandable and designed to call attention to the nature and significance of the information. 44
45 Rule on Notices of Address Discrepancy 45
46 Notices of Address Discrepancy FACT Act Section 315 FCRA Section 605(h) 16 CFR
47 Notices of Address Discrepancy Duties of users of consumer reports that receive a notice of address discrepancy from a nationwide consumer reporting agency (NCRA as defined d in FCRA) 47
48 Notices of Address Discrepancy Notice of address discrepancy notifies the user of a substantial difference between: Address the user provided, and Address in the NCRA s files 48
49 Notices of Address Discrepancy Regulatory Requirement: The user must have reasonable policies and procedures to establish a reasonable belief that the consumer report relates to the consumer about whom the report was requested 49
50 Notices of Address Discrepancy Establishing a reasonable belief Examples Compare information in the consumer report to information the user: Miti Maintains in its records Obtains from third-party sources Obtained to comply with CIP rules Verify information in the consumer report with the consumer 50
51 Notices of Address Discrepancy Regulatory Requirement: The user must have reasonable policies and procedures to furnish a confirmed address for the consumer to the NCRA, when the user: Can form a reasonable belief that the report relates to the consumer Establishes a continuing relationship with the consumer Regularly furnishes information to the NCRA 51
52 Naomi Lefkovitz Federal Trade Commission (202)
Identity Theft Prevention Program Lake Forest College Revision 1.0
Identity Theft Prevention Program Lake Forest College Revision 1.0 This document supersedes all previous identity theft prevention program documents. Approved and Adopted by: The Board of Directors Date:
More informationNEVADA SYSTEM OF HIGHER EDUCATION PROCEDURES AND GUIDELINES MANUAL CHAPTER 13 IDENTITY THEFT PREVENTION PROGRAM (RED FLAG RULES)
NEVADA SYSTEM OF HIGHER EDUCATION PROCEDURES AND GUIDELINES MANUAL CHAPTER 13 IDENTITY THEFT PREVENTION PROGRAM (RED FLAG RULES) Section 1. NSHE... 2 Section 2. UNR... 4 Section 3. WNC... 8 Chapter 13,
More informationIDENTITY THEFT RED FLAG POLICY/GUIDELINES JULY 2008
IDENTITY THEFT RED FLAG POLICY/GUIDELINES JULY 2008 Introduction: Under the Fair and Accurate Credit Transactions Act (FACT Act), financial institutions (and creditors) that offer or maintain covered accounts
More informationUNIVERSITY OF DENVER POLICY MANUAL IDENTITY THEFT PREVENTION
UNIVERSITY OF DENVER POLICY MANUAL IDENTITY THEFT PREVENTION Responsible Department: Provost and Business and Financial Affairs Recommended By: Provost, VC Business and Financial Affairs Approved By: Chancellor
More informationIdentity Theft Prevention Program. Approved by the Board of Trustees on February 20, 2009
Identity Theft Prevention Program Approved by the Board of Trustees on February 20, 2009 I. Purpose & Scope This Program was developed pursuant to the Federal Trade Commission s ( FTC ) Red Flag Rules
More informationSCOPE AND APPLICABILITY: This policy is applicable to all University faculty and staff.
SUBJECT: DETECTION OF AND RESPONSE TO IDENTITY THEFT RED FLAGS NUMBER: 412 AUTHORIZING BODY: RESPONSIBLE OFFICE: PRESIDENT S EXECUTIVE COUNCIL FINANCE AND ADMINISTRATION DATE ISSUED: OCTOBER 29, 2008 LAST
More informationLOUISIANA COMMUNITY & TECHNICAL COLLEGE SYSTEM Policy # Title: IDENTITY THEFT PREVENTION PROGRAM
LOUISIANA COMMUNITY & TECHNICAL COLLEGE SYSTEM Policy # 5.028 Title: IDENTITY THEFT PREVENTION PROGRAM Authority: Board Action Original Adoption: 02/11/2009 Effective Date: 02/11/2009 Last Revision: Initial
More informationIDENTITY THEFT DETECTION POLICY
IDENTITY THEFT DETECTION POLICY PC 6.9 Date of Last Update: May 05, 2009 Approved By: President's Cabinet Responsible Office: Business and Finance POLICY STATEMENT Grand Valley State University (GVSU)
More informationMinnesota State Colleges and Universities Identity Theft Prevention Program
Effective 3-18-09 Identity Theft Prevention Program 1 This is the Minnesota State Colleges and Universities Identity Theft Prevention Program, including more detailed guidelines. The initial Program was
More informationChristopher Newport University. Policy: Red Flag Identity Theft Identification and Prevention Program Policy Number: 3030
Christopher Newport University Policy: Red Flag Identity Theft Identification and Prevention Program Policy Number: 3030 Executive Oversight: Executive Vice President Contact Office: Comptroller s Office
More informationFitchburg State College Identity Theft Prevention Program updated 11/17/09
Fitchburg State College Identity Theft Prevention Program updated 11/17/09 Program Adoption Purpose Definitions Fitchburg State College (College) developed this Identity Theft Prevention Program to detect,
More informationNEW FTC RED FLAG REQUIREMENTS AS APPLICABLE TO CREDITORS AND COVERED ACCOUNTS
NLBMDA STAFF ANALYSIS NEW FTC RED FLAG REQUIREMENTS AS APPLICABLE TO CREDITORS AND COVERED ACCOUNTS SUMMARY The new Red Flag rule, finalized in November 2007, goes into effect on November 1, 2008. The
More information30.17 Identity Theft Protection Policy October 2018
30.17 Identity Theft Protection Policy October 2018 Preamble. The U.S. Congress has provided protection for consumers from identity theft by enacting the Fair and Accurate Credit Transactions Act ( FACTA
More informationRiverside Community College District Policy No Student Services PREVENTION OF IDENTITY THEFT IN STUDENT FINANCIAL TRANSACTIONS
Riverside Community College District Policy No. 5900 Student Services BP 5900 PREVENTION OF IDENTITY THEFT IN STUDENT FINANCIAL TRANSACTIONS Reference: Fair and Accurate Credit Transactions Act, (15 U.S.C.
More informationIdentity Theft Prevention: The FTC s Red Flags Rules and Health Care Providers HCCA Physician Practice Compliance Conference October 13, 2009
Identity Theft Prevention: The FTC s Red Flags Rules and Health Care Providers HCCA Physician Practice Compliance Conference October 13, 2009 Rebekah A. Z. Monson Pepper Hamilton LLP 215.981.4031 monsonr@pepperlaw.com
More informationMiddlebury Institute of International Studies Identity Theft Prevention Program
Middlebury Institute of International Studies Identity Theft Prevention Program I. PROGRAM ADOPTION Middlebury Institute of International Studies, hereafter referred to as the Institute, has developed
More informationWEST VIRGINIA UNIVERSITY BOARD OF GOVERNORS POLICY 54. Rule on Identity Theft Detection and Prevention Program
WEST VIRGINIA UNIVERSITY BOARD OF GOVERNORS POLICY 54 Rule on Identity Theft Detection and Prevention Program Section 1. General 1.1 Purpose: The purpose of this policy is to establish an Identity Theft
More informationPREVENTION OF IDENTITY THEFT IN STUDENT FINANCIAL TRANSACTIONS
Reference: 15 U.S. Code Section 1681m(e) (Fair and Accurate Credit Transactions Act (FACT ACT or FACTA)) I. The Purpose of the Identity Theft Prevention Program The purpose of this Identity Theft Prevention
More informationFinancial Transaction
Administrative Procedure 5800 Prevention of Identity Theft in Student Financial Transaction I. The Purpose of the Identity Theft Prevention Program The purpose of this Identity Theft Prevention Program
More informationAP 5800 PREVENTION OF IDENTITY THEFT IN STUDENT FINANCIAL TRANSACTIONS
Last Reviewed May 24, 2016 AP 5800 PREVENTION OF IDENTITY THEFT IN STUDENT FINANCIAL TRANSACTIONS Reference: 15 U.S. Code Section 1681m(e) (Fair and Accurate Credit Transactions Act (FACT ACT or FACTA))
More informationPREVENTION OF IDENTITY THEFT IN STUDENT FINANCIAL TRANSACTIONS
AP 5800 PREVENTION OF IDENTITY THEFT IN STUDENT FINANCIAL TRANSACTIONS References: 15 U.S. Code Section 1681m(e) (Fair and Accurate Credit Transactions Act (FACT ACT or FACTA)) I. The Purpose of the Identity
More informationPrevention of Identity Theft in Student Financial Transactions
AP 5800 Reference: Prevention of Identity Theft in Student Financial Transactions 15 U.S. Code Section 1681m(e) (Fair and Accurate Credit Transactions Act (FACT ACT or FACTA)) Date Issued: November 5,
More informationMiddlebury College Identity Theft Prevention Program
Middlebury College Identity Theft Prevention Program I. PROGRAM ADOPTION Middlebury College has developed this Identity Theft Prevention Program ("Program") pursuant to the Federal Trade Commission's Red
More information16 CFR Duties regarding the detection, prevention, and mitigation of identity theft.
16 CFR 681.2 681.2 Duties regarding the detection, prevention, and mitigation of identity theft. (a) Scope. This section applies to financial institutions and creditors that are subject to administrative
More informationUniversity of Cincinnati FACTA Red Flag Identity Theft Prevention Program
FACTA Red Flag Identity Theft Prevention Program FACTA Red Flag Policy Program, page 1 of 6 Contents Overview 3 Definition of Terms 3 Covered Accounts..3 List of Red Flags 3 Suspicious Documents...4 Suspicious
More informationTHE COOPER UNION FOR THE ADVANCEMENT OF SCIENCE AND ART. February 24, 2010
I. Introduction THE COOPER UNION FOR THE ADVANCEMENT OF SCIENCE AND ART RED FLAGS IDENTITY THEFT PREVENTION PROGRAM A. Purpose February 24, 2010 The Cooper Union for the Advancement of Science and Art
More informationOlivet Nazarene University Identity Theft Prevention Program
Program Adoption Olivet Nazarene University ( University ) developed this identity Theft Prevention Program ( Program ) pursuant to the Federal Trade Commission's Red Flags Rule ( Rule ), which implements
More informationUM Identity Theft Protection Policy
UM Identity Theft Protection Policy Summary/Purpose: The purpose of the UM Identify Theft Protection Policy is to establish an Identity Theft Prevention Program pursuant to the Federal Trade Commission
More informationWASHTENAW COMMUNITY COLLEGE IDENTITY THEFT DETECTION, PREVENTION, AND MITIGATION PROGRAM
WASHTENAW COMMUNITY COLLEGE IDENTITY THEFT DETECTION, PREVENTION, AND MITIGATION PROGRAM PURPOSE AND SCOPE The Identity Theft Prevention Program was developed pursuant to the Federal Trade Commission s
More informationUniversity of Connecticut IDENTITY THEFT PREVENTION PROGRAM
University of Connecticut IDENTITY THEFT PREVENTION PROGRAM I. BACKGROUND II. III. IV. PURPOSE AND SCOPE DEFINITIONS IDENTIFICATION & DETECTION OF RED FLAGS V. APPROPRIATELY RESPONDING WHEN RED FLAGS ARE
More informationJack Byrne Ford & Mercury Identity Theft Program (ITPP)
Jack Byrne Ford & Mercury Identity Theft Program (ITPP) PART ONE BACKGROUND 1. Effective Date All affected employees of Jack Byrne Ford & Mercury ( Dealership ) must comply with the terms of this policy
More informationIdentity Theft Prevention Program
Identity Theft Prevention Program In December 2008 the VSC Board of Trustees recognized that some activities of the VSC are subject to the provisions of the Fair and Accurate Credit Transactions Act (FACT
More informationChapter Five: Student Services and Operations AP 5800 PREVENTION OF IDENTITY THEFT IN STUDENT FINANCIAL TRANSACTIONS
AP 5800 PREVENTION OF IDENTITY THEFT IN STUDENT FINANCIAL TRANSACTIONS I. Purpose of the Identity Theft Prevention Program The purpose of this Identity Theft Prevention Program (ITPP) is to control reasonably
More informationADMINISTRATIVE PROCEDURE 5800 DESERT COMMUNITY COLLEGE DISTRICT
ADMINISTRATIVE PROCEDURE 5800 DESERT COMMUNITY COLLEGE DISTRICT PREVENTION OF IDENTITY THEFT IN STUDENT FINANCIAL TRANSACTIONS The purpose of this Identity Theft Prevention Program (ITPP) is to control
More informationThe Federal Identity Theft Red Flag Rules and North Carolina Local Health Departments
Health Law bulletin number 89 november 2008 The Federal Identity Theft Red Flag Rules and North Carolina Local Health Departments Jill Moore In November 2007, several federal agencies jointly issued a
More informationCalifornia State University Bakersfield Identity Theft Prevention ( Red Flag ) Implementation Plan
California State University Bakersfield Identity Theft Prevention ( Red Flag ) Implementation Plan May 28, 2010 1.0 INTRODUCTION... 3 2.0 PURPOSE... 3 3.0 DEFINITIONS... 4 4.0 THE PROGRAM... 4 4.1. Program
More informationEXHIBIT A IDENTITY THEFT PREVENTION PROGRAM
EXHIBIT A IDENTITY THEFT PREVENTION PROGRAM I. ADOPTION Michigan State University Identity Theft Prevention Program The Board of Trustees of Michigan State University adopted this Identity Theft Prevention
More informationPalomar Community College District Procedure AP 5900 PREVENTION OF IDENTITY THEFT IN STUDENT FINANCIAL TRANSACTIONS
1 STUDENT SERVICES 2 3 AP 5900 PREVENTION OF IDENTITY THEFT IN STUDENT FINANCIAL TRANSACTIONS 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 References: Fair
More informationNote: Action items are italicized
BEREA COLLEGE Red Flag Rules/ Identity Theft Prevention Policy Document No. FIN002 Effective Date 05/2009 Revision Date Pages 1-7 Approval: On File in F/A Note: Action items are italicized 1.0 Background
More informationPREVENTION OF IDENTITY THEFT IN STUDENT FINANCIAL TRANSACTIONS
BP 5800 Allan Hancock Joint Community College District Board Policy Chapter 5 Student Services BP 5800 PREVENTION OF IDENTITY THEFT IN STUDENT FINANCIAL TRANSACTIONS The District is required to provide
More informationProcedure for Identity Theft Prevention Program
Procedure for Identity Theft Prevention Program Effective Date of Procedure: November 1, 2009, revised October 19, 2010 OVERVIEW AND PURPOSE In accordance with the Federal Trade Commission s (FTC) Red
More informationIdentity Theft Prevention. Red Flags. Training Program
Identity Theft Prevention Red Flags Training Program 1 Red Flags Training Program Adoption Amendment passed in 2003 to the Fair Credit Reporting Act called The Fair and Accurate Credit Transactions Act
More informationIdentity theft detection, prevention and mitigation policy. (a) : policies and procedure for student records;
3359-11-10.8 Identity theft detection, prevention and mitigation policy. (A) Introduction. (1) The university of Akron is committed to the detection, prevention and mitigation of identity theft associated
More informationClarion University Identity Theft Prevention Program
Clarion University Identity Theft Prevention Program A) Purpose The purpose of the Identity Theft Prevention Program (Program) is to detect, prevent and mitigate identity theft in connection with any covered
More informationIdentity Theft Prevention Program (DRAFT)
Identity Theft Prevention Program (DRAFT) Subject: Revised: Effective date: Review date: Responsible Party: Financial Affairs N/A TBD Annually TBD MSU-Bozeman Vice President for Administration & Finance
More informationPOLICY: Identity Theft Red Flag Prevention
POLICY SUBJECT: POLICY: Identity Theft Red Flag Prevention It shall be the policy of the Cooperative to take all reasonable steps to identify, detect, and prevent the theft of its members personal information
More informationIdentity Theft Prevention Program
Policy Title: Identity Theft Prevention Program Policy Number: PS 992 Purpose of Policy: Applies to: To ensure compliance with federal mandates relating to identity theft. It requires creditors who have
More informationPolson/ Ronan Ambulance Service Identity Theft Prevention Program
Purpose Polson/ Ronan Ambulance is committed to providing all aspects of our service and conducting our business operations in compliance with all applicable laws and regulations. This policy sets forth
More informationIdentity Theft Prevention Program
ILLINOIS EASTERN COMMUNITY COLLEGES 0 Identity Theft Prevention Program Our mission is to deliver exceptional education and services to improve the lives of our students and to strengthen our communities.
More informationTITLE II ADMINISTRATIVE REGULATIONS IDENTITY THEFT PREVENTION PROGRAM
TITLE II ADMINISTRATIVE REGULATIONS CHAPTER 30 IDENTITY THEFT PREVENTION PROGRAM 30.01 Program The Town of Flower Mound, Texas, as a utility provider ( Utility ), has developed an Identity Theft Prevention
More informationThe New England College of Optometry Identity Theft Prevention Program October 30, 2009 _
The New England College of Optometry Identity Theft Prevention Program October 30, 2009 _ Policy Adoption The New England College of Optometry ( College ) has developed an Identity Theft Prevention Program
More informationCoreLogic Credco First American Way Poway, CA (800)
Red Flag Regulation WHAT IT IS The Red Flag Regulation implements Sections 114 and 315 of the FACT Act. It finalizes three distinct requirements two of which are relevant to automotive, RV and marine dealers,
More informationAUDIT AND FINANCE COMMITTEE Wednesday, June 17, 2009
Item: AF: A-1 AUDIT AND FINANCE COMMITTEE Wednesday, June 17, 2009 SUBJECT: REQUEST FOR APPROVAL OF FLORIDA ATLANTIC UNIVERSITY S IDENTITY THEFT PREVENTION PROGRAM. PROPOSED COMMITTEE ACTION Recommend
More informationThe Interagency Guidelines on Identity Theft Detection, Prevention and. Mitigation, commonly referred to as the Red Flag Rules, require each financial
DEVELOPING YOUR DEALERSHIP S WRITTEN PROGRAM TO DETECT, PREVENT, AND MITIGATE IDENTITY THEFT AS REQUIRED BY THE THE RED FLAG RULES AND TO RESPOND TO NOTICES OF ADDRESS DISCREPANCIES The Interagency Guidelines
More informationIllinois Eastern Community Colleges. Frontier Community College Lincoln Trail College Olney Central College Wabash Valley College
Illinois Eastern Community Colleges Frontier Community College Lincoln Trail College Olney Central College Wabash Valley College Identity Theft Prevention Program Approved by the Cabinet: February 4, 2015
More informationUniversity Identity Theft and Detection Program
NUMBER: FINA 4.12 (formerly BUSF 4.12) SECTION: SUBJECT: Administration and Finance University Identity Theft and Detection Program DATE: March 3, 2011 REVISED: March 8, 2016 Policy for: All Campuses and
More informationWashington Association of Sewer and Water Districts (WASWD) IDENTITY THEFT PREVENTION PROGRAM
IDENTITY THEFT PREVENTION PROGRAM Note: This sample identity theft prevention program is for informational purposes only. It may not be suitable for your district depending on its size, complexity and
More informationIdentity Theft Prevention Program Procedure
Identity Theft Prevention Program Procedure Procedure Number 9.6P Effective Date 6/16/2010 1.0 PURPOSE The college shall operate an Identity Theft Prevention Program (Appendix A) according to the written
More informationCITY OF ISSAQUAH. Identity Theft Prevention Program
Attachment A CITY OF ISSAQUAH Identity Theft Prevention Program Effective beginning May 1, 2009 Page 1 of 6 I. PROGRAM ADOPTION The City of Issaquah ( Utility ) developed this Identity Theft Prevention
More informationCLIENT UPDATE SEC AND CFTC ISSUE FINAL RULES ON IDENTITY THEFT PROTECTION
CLIENT UPDATE SEC AND CFTC ISSUE FINAL RULES ON IDENTITY THEFT PROTECTION WASHINGTON, DC Satish M. Kini smkini@debevoise.com Kenneth J. Berman kjberman@debevoise.com Renee M. Cipro* rmcipro@debevoise.com
More informationPOLICY SUMMARY FORM. Unit(s) Responsible for Policy Implementation: Vice President for Finance and Administration
POLICY SUMMARY FORM Policy Name: Identity Theft Prevention Policy Number: 14.5 Is this policy new, being reviewed/revised, or deleted? Review/Revise Date of last revision, if applicable: April 14, 2015
More informationAIMS COMMUNITY COLLEGE PROCEDURE IDENTITY THEFT PREVENTION - RED FLAG PROCEDURE
3-950A AIMS COMMUNITY COLLEGE PROCEDURE IDENTITY THEFT PREVENTION - RED FLAG PROCEDURE HISTORY In response to the growing threat of identity theft, the United States Congress passed the Fair and Accurate
More informationThe National Association of Community Health Centers, Inc. Issue Brief on. Complying with the FTC s Red Flag Rules. February, 2009
1/28/2009 The National Association of Community Health Centers, Inc. Issue Brief on Complying with the FTC s Red Flag Rules February, 2009 Prepared for NACHC by: Michael Glomb Feldesman Tucker Leifer Fidell,
More informationDAWSON PUBLIC POWER DISTRICT 300 South Washington Street P. O. Box Lexington, Nebraska Tel. No.- 308/324/2386 Fax No.
DAWSON PUBLIC POWER DISTRICT 300 South Washington Street P. O. Box 777 - Lexington, Nebraska - 68850 Tel. No.- 308/324/2386 Fax No.-308/324/2907 CUSTOMER POLICY IDENTITY THEFT PREVENTION I. OBJECTIVE Page
More informationEastpointe Community Credit Union Identity Theft and Deterrence Policy
Eastpointe Community Credit Union Identity Theft and Deterrence Policy Areas of Responsibility: Management/Operations Board Approval December 14, 2016 Board Review: December 14, 2016 Last Revision: December
More informationPolicy Statement. Definitions -Covered Account -Identifying Information -Identity Theft -Red Flag
Page 1 Austin Peay State University Identity Theft Prevention POLICIES Issued: March 25, 2017 Responsible Official: Vice President for Finance and Administration Responsible Office: Information Technology
More informationRed Flag! Now What? An SME s Guide for FACTA Red Flag Compliance. see} white paper
Red Flag! Now What? An SME s Guide for FACTA Red Flag Compliance see} white paper see} white paper Red Flag! Now What? If you are a large bank, credit union or credit card issuer, you are well aware of
More informationRed Flag Rule Procedures Under Princeton University s Identity Theft Prevention Program Effective: December 31, 2010
Red Flag Rule Procedures Under Princeton University s Identity Theft Prevention Program Effective: December 31, 2010 Princeton University employees are responsible for detecting Red Flags consistent with
More informationIV:07:11 IDENTITY THEFT PREVENTION POLICY SECTION 1: BACKGROUND
IV:07:11 IDENTITY THEFT PREVENTION POLICY SECTION 1: BACKGROUND The risk to Volunteer State Community College ( College ) its faculty, staff, students and other applicable constituents from data loss and
More informationRED FLAG RULES ANNUAL REPORT TO MAYOR AND COUNCIL
BOISE CITY RISK AND SAFETY SERVICESDIVISION DEPARTMENT OF FINANCE AND ADMINISTRATION RED FLAG RULES ANNUAL REPORT TO MAYOR AND COUNCIL AS REQUIRED BY SECTIONS 114 AND 315 OF THE FAIR AND ACCURATE CREDIT
More informationB. The College is considered a "creditor" under the Red Flags Rule because it defers payment for services rendered.
COLLEGE of CENTRAL FLORIDA ADMINISTRATIVE PROCEDURE Title: Identity Theft Prevention Program Procedure Page 1 of 5 Implementing Procedure For Policy # # 2.04 Date Approved: 07/07/11 Division: Administration
More informationRED FLAGS IDENTITY THEFT PREVENTION PROGRAM. Raleigh Radiology, LLC. Raleigh Radiology Associates. January 21, 2009
RED FLAGS IDENTITY THEFT PREVENTION PROGRAM Raleigh Radiology, LLC Raleigh Radiology Associates January 21, 2009 The Board of Directors of Raleigh Radiology, LLC and Raleigh Radiology Associates ( the
More informationCENTRAL MICHIGAN UNIVERSITY CHAPTER 13
POLICIES, PRACTICES AND REGULATIONS PAGE 13-20 The Board of Trustees approves and adopts the Identity Theft Red Flags Policy dated April 23, 2009 stated below. Background Central Michigan University Identity
More informationRed Flags Rule Identity Theft Training Program
Red Flags Rule Identity Theft Training Program October 2017 Purpose of Training The purpose of the UA Little Rock Identity Theft Prevention Program is to reduce the exposure of financial and personal loss
More informationAttachment to Identity Theft Prevention Service Provider Attestation
Attachment to Identity Theft Prevention Service Provider Attestation Identify Theft Prevention Policy Effective January 1, 2011 Identity Theft is a crime in which an individual wrongfully obtains and uses
More informationSubject: Identity Theft, G-113 Department: All & Branches References: Part 717, NCUA Rules and Regs, FACT Act, Companion SOP s G-30 (Opening New
Subject: Identity Theft, G-113 Department: All & Branches References: Part 717, NCUA Rules and Regs, FACT Act, Companion SOP s G-30 (Opening New Accounts), G-38 (E-Commerce), G-40 (Issuance of Visa Cards),
More informationPROCEDURE. This procedure is intended to identify third party arrangements and red flags involving College activities that will:
Subject Source PROCEDURE Identity Theft Prevention Vice President, Finance and Administrative Services Number: 1.07.02 Reference (Rule #) 6HX14-1.07 President s Approval/Date: 12/21/2017 POLICY: PURPOSE:
More informationChapter 3. Identifying Red Flags. 3:1 Overview
Chapter 3 Identifying Red Flags 3:1 Overview 3:1.1 Identity Theft 3:1.2 Red Flag 3:2 Conducting an Initial Risk Assessment 3:2.1 Practical Considerations 3:2.2 Risk Factors to Consider 3:2.3 Other Sources
More informationLexisNexis Developing an Effective Red Flags Rule Program
LexisNexis Developing an Effective Red Flags Rule Program Program Checklist R O I : R E T U R N O N I N F O R M AT I O N S O LU T I O N S Customer Development Authentication & Screening Fraud Prevention
More informationDriven. FTC Red Flags and Address Discrepancy Rules: Protecting Against Identity Theft L50 L50
Driven NADA Management series L50 A Dealer Guide to THE FTC Red Flags and Address Discrepancy Rules: Protecting Against Identity Theft L50 The National Automobile Dealers Association (NADA) has prepared
More informationORGANIZATIONAL MANUAL
I. PURPOSE ORGANIZATIONAL MANUAL IDENTITY THEFT PROTECTION A. To establish an Identity Theft Prevention Program designed to detect, prevent and mitigate Identity Theft in connection with the opening of
More informationNumber: Identity Theft Program Procedures and Protocol Responsible Office: Business and Finance
POLICY USF System USF USFSP USFSM Number: 0-109 Title: Identity Theft Program Procedures and Protocol Responsible Office: Business and Finance Date of Origin: 1-11-11 Date Last Amended: Date Last Reviewed:
More information(2) Detect red flags that have been incorporated into the program;
3341-6-56 Theft Prevention Policy (Red Flag Rules). Applicability All University units Responsible Unit Policy Administrator The Vice President for Finance and Administration and Chief Financial Officer
More informationTHE CHILDREN'S MERCY HOSPITAL ADMINISTRATIVE POLICY
THE CHILDREN'S MERCY HOSPITAL ADMINISTRATIVE POLICY TITLE: Identity Theft Prevention Program EFFECTIVE: 11/08 REVISION DATE: REVIEWED WITH NO CHANGES: 12/13 RETIRED: PURPOSE: The Identity Theft Prevention
More informationFOX VALLEY ORTHOPEDICS. Identity Compliance Program
I. ADOPTION OF WRITTEN PROGRAM ( Program ) Fox Valley Orthopedics (the Practice ) adopts this written program to assist in identifying sensitive information, as well as identifying, detecting and mitigating
More informationMedical Identity Theft Prevention Policy
SUBJECT: NUMBER: EFFECTIVE DATE: SUPERSEDES SPP: APPROVED BY: DISTRIBUTION: Medical Identity Theft Prevention Policy (signature) DATED: I. STATEMENT OF PURPOSE: To define medical identity theft and outline
More informationIDENTITY THEFT RED FLAGS AND RESPONSES
IDENTITY THEFT RED FLAGS AND RESPONSES Based on Supplement A to Appendix J Sources of Red Flags Financial institutions and creditors should incorporate relevant red flags from sources such as: Incidents
More informationIdentity Theft Prevention Program Red Flag Rule
DIVISION OF FINANCE Committed to Service Excellence Identity Theft Prevention Program Red Flag Rule Texas A&M University and Texas A&M @ Galveston CSBA Workshop May 21, 2009 Presented by Stacie Sodolak
More informationMID-CAROLINA ELECTRIC COOPERATIVE, INC. SERVICE RULES AND REGULATIONS
MID-CAROLINA ELECTRIC COOPERATIVE, INC. SERVICE RULES AND REGULATIONS 400 BILLING 401 BILLING PERIOD AND PAYMENT OF BILLS All members shall be billed monthly. All bills will include South Carolina sales
More informationIdentity Theft Prevention Program
Slide 1 Identity Theft Prevention Program Welcome to the Identity Theft Prevention Program annual training course. Your personal identification information can be used by individuals seeking to use your
More informationAHCA Memorandum. Background
AHCA Memorandum To: From: AHCA Members Elise Smith, JD Vice President Research and Reimbursement Subject: Summary of Regulations Addressing Identity Theft That Affect Nursing Facilities and Assisted Living
More informationMEMORANDUM. Red Flag Identity Theft Regulations: Implications for Nursing Facilities and Assisted Living Facilities 1
Carol C. Loepere Direct Phone: +1 202 414 9216 Email: cloepere@reedsmith.com Reed Smith LLP 1301 K Street, N.W. Suite 1100 - East Tower Washington, D.C. 20005-3373 +1 202 414 9200 Fax +1 202 414 9299 reedsmith.com
More informationADMINISTRATIVE POLICY STATEMENT
ADMINISTRATIVE POLICY STATEMENT Policy Title: Collection of Personal Data from Students and Customers APS Number: 7003 Brief Description: Effective: July 1, 2009 Approved by: APS Functional Area: RISK
More informationTempleton Municipal Light and Water Plant
Templeton Municipal Light and Water Plant RED FLAG POLICY 1. POLICY It is the policy of the Templeton Municipal Light and Water Plant (TMLWP) that information compiled on all customers and employees is
More informationHow To Protect Students Against Identity Theft and Complying with Safeguarding Regulations
How To Protect Students Against Identity Theft and Complying with Safeguarding Regulations 2017 BY: KAREN REDDICK NATIONAL CREDIT MANAGEMENT 888-692-3964 kreddick@ncmstl.com 1 WHAT DO THESE STARS HAVE
More informationSecure Opening Plus Requirements for the Identity Theft Red Flag Program
Secure Opening Plus Requirements for the Identity Theft Red Flag Program Secure Opening Plus is a solution that assists financial institutions in obtaining identifying information and opening accounts
More informationIdentity Theft: Shifting Focus from Criminals and Consumers to Businesses
Identity Theft: Shifting Focus from Criminals and Consumers to Businesses Chris Jay Hoofnagle Director, Information Privacy Programs For The John Jay College of Criminal Justice October 20, 2009 1 Thesis:
More information11/14/ FNBT FACT ACT
1 FNBT FACT ACT This class addresses the Fair Credit Reporting Act which governs the collection and use of information considered in connection with granting credit, providing insurance or offering employment.
More informationANTI-MONEY LAUNDERING ( AML ) POLICY OF BullM Global Limited
ANTI-MONEY LAUNDERING ( AML ) POLICY OF BullM Global Limited POLICY STATEMENT AND PRINCIPLES BullM Global Limited ( BULLM ) has adopted an Anti-Money Laundering (AML) compliance policy ( Policy ) according
More informationFair Credit Reporting Act
Fair Credit Reporting Act Compliance Bankers for Compliance School DEPOSITS 2016 This publication is designed to provide information in regard to the subject matter covered. It is provided with the understanding
More information