Spotting ID Theft Red Flags A Guide for FACTA Compliance. An IDology, Inc. Whitepaper

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1 Spotting ID Theft Red Flags A Guide for FACTA Compliance An IDology, Inc. Whitepaper

2 With a November 1 st deadline looming for financial companies and creditors to comply with Sections 114 and 315 of the Fair and Accurate Transactions Act of 2003 (FACTA), also known as Red Flag regulations, many are scrambling to understand how the new rules affect their company let alone how to meet them. At a basic level, Red Flag regulations require financial institutions and creditors to develop and deploy an Identity Theft Prevention Program to combat id theft on new and existing accounts. The ultimate goal is to reduce the billions of dollars individuals and businesses lose to identity theft each year, which according to a 2008 study published by Javelin Strategy & Research totaled $45 billion in There are 26 specific Red Flag examples to consider if your business is subject to the FACTA rules, which according to the Federal Trade Commission (FTC) could even include someone who obtains a credit report on a prospective nanny. 2 However, depending on your business, you could have more than 26. Detecting and preventing identity theft is a lot easier and less costly than you think when you have a clear understanding on how to best address the different categories under Red Flag. The good news is you probably have several procedures already in place to detect fraud and there are new technologies that you can easily deploy to cover areas you still need to address. This whitepaper is designed to serve as a guide to compliance so that you can easily put your Identity Theft Prevention Plan into action. 1. Javelin Strategy & Research Report, 2008 Identity Fraud Survey Report, Consumer Version, February 2008, p Robert Mullins Contributor, FACTA s red flags of identity theft, Compliance and Governance Digest, February 2008 page

3 Determining If Red Flag Compliance Applies To You Essentially you are required to comply with FACTA if you maintain financial information on consumers. Under the final Red Flag rules, only those financial institutions and creditors that offer and maintain covered accounts must develop and implement a Program. Companies that must comply include: Banks Credit Unions Mortgage Brokers Auto Dealers Debt Collectors Credit Issuers Utility Companies Telecommunications Companies Healthcare Companies If you are reading this paper, perhaps you already know your company needs to comply. Being able to do so is going to take input and effort from several different resources within your business including Compliance, Sales, Customer Service, IT, Fraud Departments and ultimately your Executive Officers and Board of Directors. Defining a Covered Account:. An account primarily for personal, family, or household purposes that involves or is designed to permit multiple payments or transactions; (e.g. checking account, credit card, mortgage or auto loan, phone or utility bill etc.) 2. Any other account where there is a reasonably foreseeable risk to customers or the safety and soundness of the financial institute or creditor from identity theft page 2

4 Understanding the Basic Elements of Red Flag The final regulations list four basic elements financial institutions and creditors must include in their Program to detect and prevent identity theft. These are: Identify relevant Red Flags for covered accounts and incorporate these into the Program Detect Red Flags that have been incorporated in the Program Respond appropriately to any Red Flags that are detected to prevent and mitigate identity theft Ensure the Program is updated periodically, to reflect changes in risk to customers or to the safety and soundness of the financial institution or creditor from identity theft. 5 Steps to Compliance Step 1: Identify the Red Flags for Your Business Employees of fraud departments know there are specific activities and patterns to watch that indicate possible identity fraud. The key is being able to understand what is relevant in your business. Because situations are unique, the regulations allow each company to define their own Red Flags but have outlined several consideration factors. These are: Risk Factors What types of covered accounts do you offer? How are new accounts opened and then accessed? How much data do you require from your customers when opening accounts? Where do you store data? Are accounts linked to people using social security numbers or some other type of identifier? Red Flag Sources Can you pinpoint specific incidents of identity theft? Does the method of the incidence change any of your risk factors? What about factoring in new methods criminals might use? page 3

5 Red Flag Categories Have you addressed all the situations that might appear in each Red Flag category of the regulations? The more comprehensive your scenario list is, the better prepared you will be for detecting fraud. Appended to the regulations are 26 illustrative examples which serve as a great guide. Refer to the Examining Red Flag Categories & How to Address Them section of this paper for a complete list. Step 2: Detecting Red Flags It is much easier to know how to detect possible identity theft when you have an understanding about the common signs of fraud in your business. Once you have completed your list of Red Flags, you can examine each one individually to determine the best way to detect when Red Flags occur. Detection can be separated by customer type. For example: New Customers you need to be able to verify the identity of the person and know they are who they say they are before you open a new account, no matter if the account is being opened in person or online. One effective way that works in both situations is to use an identity verification solution with challenge questions. Just be sure to select a provider that offers out-of-wallet questions based on personal knowledge. This prevents people from being able to answer the questions by stealing a purse or wallet or even a piece of mail. Your verification provider should also be able to detect different Red Flags such as a social security number is invalid or an address does not match the name provided. Existing Customers to protect your existing customers the Program must include methods to authenticate the person accessing a covered account whether it is online or in-person. Several authentication technologies are available but again, identity verification is effective in this situation. Other authentication techniques that might be more difficult to deploy but are also effective are biometrics, tokens, and out-of-band verification solutions, however, some of these do not have the added benefit of being able to detect identity issues when new accounts are being opened. Your Program will probably use a combination of authentication methods depending on the different risk factors. Another Red Flag detection method for existing covered accounts is to monitor transactions to pinpoint suspicious behavior such as a noticeable change in funds being transferred from deposit accounts, high credit card purchases made from different cities in a short span of time, and most importantly a change of address request. page 4

6 Change of address requests are significant because this is one way criminals try to hide their activity. By having bills or statements sent to a different address, the true owner of the identity or account goes unaware. Under the new regulations credit cards and debit card issuers are specifically required to verify the validity of a change of address request within 30 days. Step 3: Responding to a Red Flag Alert Considering the regulations were passed to reduce identity theft, how your business responds to Red Flags when detected is a critical component. Since Red Flags will differ in each company, you are only required to provide an appropriate response that is equal with the degree of risk posed. Determining an appropriate response depends on other factors that might raise the risk of identity theft such as a data security breach, phishing scheme, or some other method the criminals invent. Appropriate responses may include monitoring covered accounts, contacting the customer, declining to open a new account, changing access to a covered account, closing or suspending a covered account, stopping debt collections on a covered account, notifying law enforcement and also no response in situations where warranted. Real-life examples of Red Flags: Consumer fails to answer challenge questions about places they have lived or people they know Person makes a substantial withdrawal from a savings or checking account or deposits a lot of money into a newly opened account High dollar credit card purchases on the same day in different cities Social security number and address discrepancies are found when verifying an identity Description does not match the picture on a driver s license Social security number belongs to a deceased person page 5

7 Step 4: Plan to Review and Update Your Program Periodically Because the fraud landscape changes quickly, you need to monitor your Program so that you can adapt it as necessary. You need to be flexible so that you are able to stay ahead of the criminals and protect both consumers and your business. Critical factors to monitor outlined in the regulations include the number of incidences of identity theft, the changing methods of criminals, changes to the types of accounts your company offers, changes in detection technologies and methods, and changes in your business arrangements such as mergers, alliances, contracted service providers etc. It is a good idea to assign a Program task force or committee and make them responsible for meeting on a regular basis to review the Program and analyze its effectiveness. This committee should include different representatives within your Company responsible for covered accounts. You might also want to include marketing, training and HR representatives as well depending on the size of your business so that on-going awareness campaigns and appropriate training materials can quickly be created or updated as procedures and policies change. Step 5: Put Your Plan Into Action It is now time to administer your Program especially if there are certain elements that are not already implemented. The regulations break down Program administration into three areas: Overseeing the Program your initial Program must be approved and adopted by either a Board of Directors, a committee of the Board, or a Senior Management employee. Responsibilities include assigning tasks to implement the Program, reviewing Program reports and approving any changes that are made to the Program. Reporting the assigned staff responsible for implementing the Program are required to report at least annually on compliance to the board, committee or employee overseeing the Program. Reports are required to cover the effectiveness of the procedures and policies as it relates to the covered accounts including service provider arrangements, a review of significant incidents of id theft and the company s response and any recommendations for changes within the Program. page 6

8 Overseeing Service Providers service providers connected to your company s covered accounts fall under your responsibility and you need to take the steps to make sure their activity is in accordance with reasonable policies and procedures for detecting, preventing and reducing the incidences of identity theft. You will want to create a checklist and a timeline for implementing any elements that are not already standard procedure. If you are considering new service providers you should factor in their timeline for implementation. Ideally, the service providers you select will be able to have you up and running quickly and well before the compliance deadline. Examining Red Flag Categories & How to Address Them While financial institutions and creditors are allowed to define their own Red Flags, the regulations outline five categories to address and through an appended supplement provide illustrative examples in each category that are fairly comprehensive. On the following pages is a breakdown of the 26 examples by category as well as a resource guide for detecting Red Flags and some possible responses. When developing your response procedures you need to consider the type of covered account of the Red Flag because the action you take can be different and might affect customer satisfaction levels in your business. Keep in mind also that in certain situations, no response might be warranted. page 7

9 Alerts, Notifications or Warnings from a Consumer Reporting Agency Red Flag Detected By Possible Responses A fraud or active duty alert is included with a consumer report. A consumer reporting agency provides a notice of credit freeze in response to a request for a consumer report. A consumer reporting agency provides a notice of address discrepancy. A consumer report indicates a pattern of activity that is inconsistent with the history and usual pattern of activity of an applicant or customer, such as: A recent and significant increase in the volume of inquiries; An unusual number of recently established credit relationships; A material change in the use of credit, especially with respect to recently established credit relationships; or An account that was closed for cause or identified for abuse of account privileges by a financial institution or creditor. Take additional steps to verify identity; Flag relevant accounts and monitor activity; Decline account applications; Validate addresses Helpful Tip: Make sure your s are trained to analyze activity on consumer credit reports before issuing credit or setting up an account. You should also be sure the credit bureaus you use comply with Red Flag regulations and are protecting consumers from identity theft as well. Suspicious Documents Red Flag Detected By Possible Responses Documents provided for identification appear to have been altered or forged. The photograph or physical description on the identification is not consistent with the appearance of the applicant or customer presenting the identification. Other information on the identification is not consistent with information provided by the person opening a new covered account or customer presenting the identification. Other information on the identification is not consistent with readily accessible information that is on file with the financial institution or creditor, such as a signature card or a recent check. An application appears to have been altered or forged, or gives the appearance of having been destroyed and reassembled. Verify using identity verification solution; Decline the application; Notify law enforcement if necessary Helpful Tip: Do not limit your training efforts to new employees. Involve your communications department to create awareness campaigns about identity theft prevention so that all your employees are prepared to spot fraud. page 8

10 Suspicious Personal Identifying Information Red Flag Detected By Possible Responses Personal identifying information provided is inconsistent when compared against external information sources used by the financial institution or creditor. For example: The address does not match any address in the consumer s data file; or The Social Security Number (SSN) has not been issued, or is listed on the Social Security Administration s Death Master File. Personal identifying information provided by the customer is not consistent with other personal identifying information provided by the customer. For example, there is a lack of correlation between the SSN range and date of birth. Personal identifying information provided is associated with known fraudulent activity as indicated by internal or third-party sources used by the financial institution or creditor. For example: The address on an application is the same as the address provided on a fraudulent application; or The phone number on an application is the same as the number provided on a fraudulent application. Personal identifying information provided is of a type commonly associated with fraudulent activity as indicated by internal or third-party sources used by the financial institution or creditor. For example: The address on an application is fictitious, a mail drop, or a prison; or The phone number is invalid, or is associated with a pager or answering service. The SSN provided is the same as that submitted by other persons opening an account or other customers. The address or telephone number provided is the same as or similar to the account number or telephone number submitted by an unusually large number of other persons opening accounts or other customers. The person opening the covered account or the customer fails to provide all required personal identifying information on an application or in response to notification that the application is incomplete. Personal identifying information provided is not consistent with personal identifying information that is on file with the financial institution or creditor. For financial institutions and creditors that use challenge questions, the person opening the covered account or the customer cannot provide authenticating information beyond that which generally would be available from a wallet or consumer report. Escalate identity verification to a higher level; Decline to open the account; Stop processing the request; Notify Customers Involved; Change account information when necessary; Involve law enforcement Helpful Tip: An identity verification integrated solutions means less time required from your employees to manually review transactions. Find a solution that goes beyond simple pass/fail rates so that you can quickly determine how to handle suspicious transactions. page

11 Unusual Use of, or Suspicious Activity Related to, the Covered Account Red Flag Detected By Possible Responses Shortly following the notice of a change of address for a covered account, the institution or creditor receives a request for a new, additional, or replacement card or a cell phone, or for the addition of authorized users on the account. A new revolving credit account is used in a manner commonly associated with known patterns of fraud patterns. For example: The majority of available credit is used for cash advances or merchandise that is easily convertible to cash (e.g., electronics equipment or jewelry); or The customer fails to make the first payment or makes an initial payment but no subsequent payments. A covered account is used in a manner that is not consistent with established patterns of activity on the account. There is, for example: Nonpayment when there is no history of late or missed payments; A material increase in the use of available credit; A material change in purchasing or spending patterns; A material change in electronic fund transfer patterns in connection with a deposit account; or A material change in telephone call patterns in connection with a cellular phone account. A covered account that has been inactive for a reasonably lengthy period of time is used (taking into consideration the type of account, the expected pattern of usage and other relevant factors). Mail sent to the customer is returned repeatedly as undeliverable although transactions continue to be conducted in connection with the customer s covered account. The financial institution or creditor is notified that the customer is not receiving paper account statements. The financial institution or creditor is notified of unauthorized charges or transactions in connection with a customer s covered account. or or Fraud Department Fraud Department Fraud Department Fraud Department Fraud Department Fraud Department Use out of wallet challenge questions when change of address is initiated online or in a call center; Contact the customer to validate address change requests or purchases; Suspend the account; Monitor the account; Change passwords to access the account or re-open an account with a new number; Notify law enforcement Helpful Tip: Use technology products that help identify suspicious activity. A pattern of activity that looks similar across several accounts or locations could indicate a fraud ring. Be sure you involve law enforcement as early as possible to increase the chances of apprehending suspects. page 10

12 Notice from Customers, Victims of Identity Theft, Law Enforcement Authorities, or Other Persons Regarding Possible Identity Theft in Connection with Covered Accounts Held by the Financial Institution or Creditor Red Flag Detected By Possible Responses The financial institution or creditor is notified by a customer, a victim of identity theft, a law enforcement authority, or any other person that it has opened a fraudulent account for a person engaged in identity theft. Fraud Department Close the existing fraudelent account, Reopen a covered account with a new account number; Do not attempt to collect on the fraudulent account from the true identity owner; Cooperate with law enforcement; Helpful Tip: Update your company s crisis communications training to encompass the way spokespeople handle the situation when it is severe enough to attract media attention. Determine the chain of command for those authorized to speak on behalf of the company and keep a comprehensive contact list on them. About IDology, Inc. IDology s identity and age verification solutions help companies detect and prevent fraud while driving revenue and decreasing costs. Using its ExpectID product suite, financial institutes and creditors can verify an individual s identity and age online, in a call center or through a mobile device, in real-time without interrupting the transaction. IDology s solutions make complying with new Red Flag regulations easy by providing more than simple pass/fail rates with verifications. This allows businesses to quickly detect and respond to suspicious activity including offering out-ofwallet questions that prove someone is who they claim to be. IDology s verification process is unique because it is done in way that builds more confidence with your customers by protecting sensitive data and promoting consumer privacy. And IDology is the only provider to offer an on-demand change management tool that allows client business unit managers to manage and control the entire proofing process without having to rely on internal IT resources or contact IDology s customer service. For more information, visit or call page 11

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