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Page 1: Are You Ready? Identity fraud and identity management are quickly becoming critical operational concerns for the financial industry. The Red Flags Guidelines
Page 2: Are You Ready? Identity fraud and identity management are quickly becoming critical operational concerns for the financial industry. The Red Flags Guidelines

Are You Ready?Are You Ready?Identity fraud and identity

management are quickly becoming critical operational concerns for the financial industry. The Red Flags Guidelines issued in October 2007 pursuant to the Fair and Accurate Credit Transactions Act requires implementation of an Identity Theft Prevention Program by November 1, 2008.

Identity fraud and identity management are quickly becoming critical operational concerns for the financial industry. The Red Flags Guidelines issued in October 2007 pursuant to the Fair and Accurate Credit Transactions Act requires implementation of an Identity Theft Prevention Program by November 1, 2008.

Page 3: Are You Ready? Identity fraud and identity management are quickly becoming critical operational concerns for the financial industry. The Red Flags Guidelines

What is ID TheftWhat is ID Theft

“Identity Theft” has the same meaning as under 16 CFR 603.2(a)

• “A fraud committed or attempted using the identifying information of another person without authority.”

“Identity Theft” has the same meaning as under 16 CFR 603.2(a)

• “A fraud committed or attempted using the identifying information of another person without authority.”

Page 4: Are You Ready? Identity fraud and identity management are quickly becoming critical operational concerns for the financial industry. The Red Flags Guidelines

Legislation covers three main areas:Legislation covers three main areas:

• Address Discrepancies• Recipients of credit reports now must take action upon

receipt of Address Discrepancy Indicators (ADI) with credit reports.

• Red Flags• Red Flag Rules require development and implementation of

a written Identity Theft Prevention Program to detect, prevent and mitigate identity theft.

• Duty of Card Issuers• Card issuers that receive a change of address notice may not issue

new cards within 30 days unless the address is validated.

• Address Discrepancies• Recipients of credit reports now must take action upon

receipt of Address Discrepancy Indicators (ADI) with credit reports.

• Red Flags• Red Flag Rules require development and implementation of

a written Identity Theft Prevention Program to detect, prevent and mitigate identity theft.

• Duty of Card Issuers• Card issuers that receive a change of address notice may not issue

new cards within 30 days unless the address is validated.

Page 5: Are You Ready? Identity fraud and identity management are quickly becoming critical operational concerns for the financial industry. The Red Flags Guidelines

Legislation covers three main areas:Legislation covers three main areas:

• Address Discrepancies• Recipients of credit reports now must take action upon

receipt of Address Discrepancy Indicators (ADI) with credit reports.

• Red Flags• Red Flag Rules require development and implementation of

a written Identity Theft Prevention Program to detect, prevent and mitigate identity theft.

• Duty of Card Issuers• Card issuers that receive a change of address notice may not issue

new cards within 30 days unless the address is validated.

• Address Discrepancies• Recipients of credit reports now must take action upon

receipt of Address Discrepancy Indicators (ADI) with credit reports.

• Red Flags• Red Flag Rules require development and implementation of

a written Identity Theft Prevention Program to detect, prevent and mitigate identity theft.

• Duty of Card Issuers• Card issuers that receive a change of address notice may not issue

new cards within 30 days unless the address is validated.

Page 6: Are You Ready? Identity fraud and identity management are quickly becoming critical operational concerns for the financial industry. The Red Flags Guidelines

What is a Red Flag?What is a Red Flag?A pattern, practice, or specific activity that indicates the

possible existence of identity theft.Affects both new and existing accounts.

Red Flag Categories Alerts, notifications or warnings from a CRA Suspicious documents Suspicious personal identifying information Unusual use of, or suspicious activity relating to, the

covered account Notices from customer, victims of ID theft, law

enforcement authorities, or other persons regarding possible ID theft in connection with covered accounts held by the organization

A pattern, practice, or specific activity that indicates the possible existence of identity theft.

Affects both new and existing accounts.

Red Flag Categories Alerts, notifications or warnings from a CRA Suspicious documents Suspicious personal identifying information Unusual use of, or suspicious activity relating to, the

covered account Notices from customer, victims of ID theft, law

enforcement authorities, or other persons regarding possible ID theft in connection with covered accounts held by the organization

Page 7: Are You Ready? Identity fraud and identity management are quickly becoming critical operational concerns for the financial industry. The Red Flags Guidelines

Red Flag RequirementsRed Flag RequirementsFour basic elements of an Identity Theft Prevention

Program (ITPP):

• Identify

• Detect

• Respond

• Update

Four basic elements of an Identity Theft Prevention Program (ITPP):

• Identify

• Detect

• Respond

• Update

Page 8: Are You Ready? Identity fraud and identity management are quickly becoming critical operational concerns for the financial industry. The Red Flags Guidelines

Red Flag RequirementsRed Flag RequirementsFour basic elements of an Identity Theft Prevention

Program (ITPP):

• Identify

• Detect

• Respond

• Update

Four basic elements of an Identity Theft Prevention Program (ITPP):

• Identify

• Detect

• Respond

• Update

Page 9: Are You Ready? Identity fraud and identity management are quickly becoming critical operational concerns for the financial industry. The Red Flags Guidelines

To achieve compliance:To achieve compliance:– Perform a risk assessment to identify all covered accounts

– For each covered account, identify relevant red flags that may indicate possible identity theft

– For each red flag, identify appropriate detection and response procedures to detect and prevent possible identity theft

– Develop a written identity theft prevention program

– Obtain board of directors approval of the program

– Provide training to appropriate staff

– Monitor changes in identity theft and update program periodically

– Oversee service provider arrangements

– Review the program at least annually

– Perform a risk assessment to identify all covered accounts

– For each covered account, identify relevant red flags that may indicate possible identity theft

– For each red flag, identify appropriate detection and response procedures to detect and prevent possible identity theft

– Develop a written identity theft prevention program

– Obtain board of directors approval of the program

– Provide training to appropriate staff

– Monitor changes in identity theft and update program periodically

– Oversee service provider arrangements

– Review the program at least annually

Page 10: Are You Ready? Identity fraud and identity management are quickly becoming critical operational concerns for the financial industry. The Red Flags Guidelines

Five Common Mistakes and PitfallsFive Common Mistakes and Pitfalls

1. Approach compliance like any other Rule

2. Simply update existing Information Security Program

3. Consider all accounts as covered, include all 26 Red Flags

4. Ignore service providers, business partners.

5. Forget to implement periodic Program update process

1. Approach compliance like any other Rule

2. Simply update existing Information Security Program

3. Consider all accounts as covered, include all 26 Red Flags

4. Ignore service providers, business partners.

5. Forget to implement periodic Program update process

Page 11: Are You Ready? Identity fraud and identity management are quickly becoming critical operational concerns for the financial industry. The Red Flags Guidelines

Five Common Mistakes and PitfallsFive Common Mistakes and Pitfalls

1. Approach compliance like any other Rule

2. Simply update existing Information Security Program

3. Consider all accounts as covered, include all 26 Red Flags

4. Ignore service providers, business partners.

5. Forget to implement periodic Program update process

1. Approach compliance like any other Rule

2. Simply update existing Information Security Program

3. Consider all accounts as covered, include all 26 Red Flags

4. Ignore service providers, business partners.

5. Forget to implement periodic Program update process

Page 12: Are You Ready? Identity fraud and identity management are quickly becoming critical operational concerns for the financial industry. The Red Flags Guidelines

What are the consequences?What are the consequences?

Non-compliance penalties can include:

• Civil Money Penalty for Each Violation

• Cease and Desist Order

• Lowering of Examination Rating

• Negative Publicity, Loss of Business

• Consumer Lawsuit

Non-compliance penalties can include:

• Civil Money Penalty for Each Violation

• Cease and Desist Order

• Lowering of Examination Rating

• Negative Publicity, Loss of Business

• Consumer Lawsuit

Page 13: Are You Ready? Identity fraud and identity management are quickly becoming critical operational concerns for the financial industry. The Red Flags Guidelines

Alerts, Notifications or Warnings from a Consumer Reporting AgencyAlerts, Notifications or Warnings from a Consumer Reporting Agency

1. Fraud or active duty alert2. Credit freeze3. Address discrepancy4. Inconsistent activity pattern

1. Fraud or active duty alert2. Credit freeze3. Address discrepancy4. Inconsistent activity pattern

Page 14: Are You Ready? Identity fraud and identity management are quickly becoming critical operational concerns for the financial industry. The Red Flags Guidelines

Alerts, Notifications or Warnings from a Consumer Reporting AgencyAlerts, Notifications or Warnings from a Consumer Reporting Agency

1. Fraud or active duty alert2. Credit freeze3. Address discrepancy4. Inconsistent activity pattern

1. Fraud or active duty alert2. Credit freeze3. Address discrepancy4. Inconsistent activity pattern

Page 15: Are You Ready? Identity fraud and identity management are quickly becoming critical operational concerns for the financial industry. The Red Flags Guidelines

Suspicious Personal Identifying

Information Suspicious Personal Identifying

Information

10.Personal ID info inconsistent with external information

11.Personal ID info inconsistent with other ID info

10.Personal ID info inconsistent with external information

11.Personal ID info inconsistent with other ID info

Page 16: Are You Ready? Identity fraud and identity management are quickly becoming critical operational concerns for the financial industry. The Red Flags Guidelines

Suspicious Personal Identifying Information, continued

Suspicious Personal Identifying Information, continued

12.Personal ID info associated with known fraud

13.Personal ID info is type commonly associated with fraud

14.Duplicate SSN

12.Personal ID info associated with known fraud

13.Personal ID info is type commonly associated with fraud

14.Duplicate SSN

Page 17: Are You Ready? Identity fraud and identity management are quickly becoming critical operational concerns for the financial industry. The Red Flags Guidelines

Suspicious Personal Identifying Information, continued

Suspicious Personal Identifying Information, continued

15.Duplicate address or telephone number

16.Incomplete required info

17.Personal ID info inconsistent with info on file

18.Inability to correctly authenticate via challenge questions

15.Duplicate address or telephone number

16.Incomplete required info

17.Personal ID info inconsistent with info on file

18.Inability to correctly authenticate via challenge questions

Page 18: Are You Ready? Identity fraud and identity management are quickly becoming critical operational concerns for the financial industry. The Red Flags Guidelines

Red Flag ScopeRed Flag ScopeSome rules are flexible:

• Creditors can tailor program to fit the size/complexity of operation

• Creditors can incorporate existing policies and procedures • Creditors should consider all 26 example

Red Flags across the five categories• Creditors should include the Red Flags

that make sense in the context of their businesses

More fine print:Each financial institution is responsible for making

subjective determination of applicability of regulations for their customers/accounts

Some rules are flexible:• Creditors can tailor program to fit the size/complexity of

operation• Creditors can incorporate existing policies and procedures • Creditors should consider all 26 example

Red Flags across the five categories• Creditors should include the Red Flags

that make sense in the context of their businesses

More fine print:Each financial institution is responsible for making

subjective determination of applicability of regulations for their customers/accounts

Page 19: Are You Ready? Identity fraud and identity management are quickly becoming critical operational concerns for the financial industry. The Red Flags Guidelines

Some Helpful Web LinksSome Helpful Web Linkshttp://www.bankersonline.com/redflags/sr222appj_suppa.html

http://www.bankersonline.com/regs/222/222-90.html

http://www.bankersonline.com/redflags/focus_sis_redflagchecklist.html

http://www.fdic.gov/news/news/financial/2007/fil07100.html for FDIC FIL-100-2007 (Identity Theft Red Flags)

http://www.occ.treas.gov/ftp/bulletin/2007-45.html to view OCC Bulletin 2007-45 (Identity Theft Red Flags and Address Discrepancies)

http://www.ots.treas.gov/docs/7/777079.html to view OTS 07-079 (Agencies Issue Final Rules on Identity Theft Red Flags and Notices of Address Discrepancy)

http://www.bankersonline.com/redflags/sr222appj_suppa.html

http://www.bankersonline.com/regs/222/222-90.html

http://www.bankersonline.com/redflags/focus_sis_redflagchecklist.html

http://www.fdic.gov/news/news/financial/2007/fil07100.html for FDIC FIL-100-2007 (Identity Theft Red Flags)

http://www.occ.treas.gov/ftp/bulletin/2007-45.html to view OCC Bulletin 2007-45 (Identity Theft Red Flags and Address Discrepancies)

http://www.ots.treas.gov/docs/7/777079.html to view OTS 07-079 (Agencies Issue Final Rules on Identity Theft Red Flags and Notices of Address Discrepancy)

Page 20: Are You Ready? Identity fraud and identity management are quickly becoming critical operational concerns for the financial industry. The Red Flags Guidelines

Questions?Questions?