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1 1 FACTA Identity Theft Red Flags Program

2 Module 1 Fair and Accurate Credit Transactions Act Overview Identity thieves use individual s personal identifiable information to open new accounts and misuse existing accounts, creating havoc for consumers and businesses. Financial institutions and creditors will be required to implement a program to identify, detect, respond, prevent and mitigate identity theft risks known as red flags. Identity theft is a growing concern that ultimately erodes the fabric of one of our most consumable critical infrastructures under homeland security our financial industry. Many security departments, fraud departments, or corporate investigative departments will be required to develop and implement an identity theft red flags program, or at a minimum, assist with assessing the identity theft risk to their organizations. This course will provide you with an overview of assessing, developing and implementing a red flags program. 2

3 Course Outline 1 Fair and Accurate Credit Transaction Act 2 Identity Theft Red Flags under FACTA 3 Development and implementation of an Identity Theft Red Flags Prevention Program 4 Maintenance of an Identity Theft Red Flags Prevention Program 5 Final Examination 3

4 Module 1 1 Fair and Accurate Credit Transactions Act What is Fair and Accurate Credit Transactions Act of 2003? Who must comply with FACTA? What are the penalties for non-compliance? Module 1 Checkpoint Assessment 4

5 Module 1 Fair and Accurate Credit Transactions Act What is FACTA? The Fair and Accurate Credit Transactions Act of 2003, is also known as FACTA or FACT Act. The Fair and Accurate Credit Transactions Act (FACT Act) was enacted in 2003 and amends the Fair Credit Reporting Act (FCRA), a federal law that regulates, in part, who is permitted to access your consumer report information and how it can be used. Section 114 and Section 315 of FACTA is related to Identity Theft Prevention and Address Discrepancies for identity theft red flags. FACTA requires each financial institution or creditor to develop and implement a written identity theft prevention program. 5

6 Module 1 Fair and Accurate Credit Transactions Act What is Section 114 (Special Rules for Card Issuers) under FACTA? Section 114 of FACTA requires the agencies to jointly issue guidelines for financial institutions and creditors regarding identity theft. Section 114 requires establishing reasonable procedures that Assist creditors and financial institutions in identifying identity theft; and Set forth provisions specifically applicable to debit and credit card issuers who receive notice of a customer s change of address. Section 114 is also known as Special Rules for Card Issuers 6

7 Module 1 Fair and Accurate Credit Transactions Act What is Section 315 (Address Discrepancy Rules) under FACTA? Section 315 of the FACTA amends section 605 of the FCRA, 15 United States Code, 1681 c, requires providing a notice of the existence of a discrepancy if the address provided by the customer/accountholder in its request substantially differs from the address of the consumer reporting agency in its consumer file for the customer accountholder. Section 315 requires procedures to handle a notice of address discrepancy Requires users of credit reports to establish reasonable procedures for handling a notice of a significant discrepancy between a credit report and application for credit 7

8 Module 1 Fair and Accurate Credit Transactions Act What Agencies Promulgated the Red Flags Rules? There were six federal agencies involved in promulgating identity theft red flags rules: Department of Treasury - Office of the Comptroller of the Currency under 12 Code of Federal Regulation (CFR) Part 41, Federal Reserve System under 12 CFR Part 222, Federal Deposit Insurance Corporation under 12 CFR Parts 334 and 364, Department of the Treasury Office of Thrift Supervision under 12 CFR Part 717, National Credit Union Administration under 12 CFR Part 717, and Federal Trade Commission under 16 CFR

9 Module 1 Fair and Accurate Transactions Act There are two core areas of developing and implementing a FACTA identity theft red flags program as follows: Establishing a written program, including a program risk assessment and a program charter. Administering the program. Identifying relevant red flags, Detecting red flags, Responding to red flags, Preventing and mitigating identity theft, and Updating the program Establishing an identity theft training program Oversight of service provider arrangements Oversight of the development, implementation and administration of the program (i.e. Compliance Officer or Chief Identity Theft Officer) Obtaining approval of the initial written program by the Board of Directors Address Discrepancy Rules Special Rules for card issuers 9

10 Module 1 Fair and Accurate Credit Transactions Act What is the Guidance under FACTA? Red Flag Rules apply to financial institutions and creditors with covered accounts with no regard whether credit reports are obtained. Appendix J to Part 571- provides interagency guidelines on Identity Theft Detection, Prevention and Mitigation. Appendix J of the red flags rule lists examples of possible patterns, practices and forms of activities creditors should consider when implementing a written identity theft prevent program. 10

11 Module 1 Fair and Accurate Credit Transactions Act Who Must Comply With Red Flags Rules? Financial Institutions Financial institutions are defined as a state or national bank, a state or federal savings and loan association, a mutual savings bank, a state or federal credit union, or any other entity that holds a transaction account belonging to a consumer. Most of these institutions are regulated by federal bank regulatory agencies or National Credit Union Administration (NCUA). This definition also includes financial institutions under the Federal Trade Commission s (FTC) jurisdiction, which includes chartered credit unions and certain other entities that hold consumer transaction accounts. 11

12 Module 1 Fair and Accurate Credit Transactions Act What Must Comply With Red Flag Rules? Creditors Creditors are any entity that regularly extend, renew, or continue credit; any entity that regularly arranges for the extension, renewal, or continuation of credit; or any assignee of an original creditor who is involved in the decision to extend, renew or continue credit. Accepting credit cards as a form of payment doe not in and of itself make an entity a creditor. For example, creditors include finance companies, financial institutions, automobile dealers, mortgage brokers, hospitals, mortgage bankers, non-banking financial services companies, utility companies and telecommunication companies to name a few. Most creditors, except for those regulated by federal banking regulatory agencies and NCUA, fall under the jurisdiction of the FTC. It is estimated that FACTA identity theft red flags rules may potentially impact 11 billion businesses. 12

13 Module 1 Fair and Accurate Credit Transactions Act What are Covered Accounts Under FACTA? Covered Accounts are accounts used mostly for personal, family or household purposes, that involve multiple payments or transactions. Covered accounts include credit card accounts, mortgage loans, automobile loans, margin accounts, cell phone accounts, utility accounts, checking accounts, and savings accounts. A covered account is also an account for which there is a foreseeable risk of identity theft for example, small business or sole proprietorship accounts. Any other account that the financial institution or creditor offers or maintains for which there is a reasonably foreseeable risk to customers or to the safety and soundness of the financial institution or creditor from identity theft, including financial, operational, compliance, reputation, or litigation risks. 13

14 Module 1 Fair and Accurate Credit Transactions Act What are Transaction Accounts Under FACTA? Transaction Accounts are a deposit or other account from which the owner makes payments or transfers. Transaction Accounts include checking accounts, negotiable order of withdrawal accounts, savings deposits subject to automatic transfers, and share draft accounts. 14

15 Module 1 Fair and Accurate Credit Transactions Act What are the Penalties for Non-Compliance to Red Flags? Federal Enforcement by the Federal Trade Commission (FTC Act, Title V) may bring an enforcement action up to $2,500 in penalties for each violation of the red flag rule. State Enforcement by the State Attorney General s Office - may recover up to $1,000 for each violation plus attorneys fees. Civil Lawsuits by Consumers - may be entitled to recover actual damages sustained from a violation of the red flag rule, plus attorney fees. 15

16 Module 1 Fair and Accurate Credit Transactions Act What are Some of the Benefits of Complying to Red Flags? Customer trust for protecting their personal identifiable information Reduction in risk for negative publicity Reduction in risk to covered accounts 16

17 Module 1 Fair and Accurate Credit Transactions Act What are Some of the Benefits of Complying to Red Flags? Reduction in risk of lawsuit Reduction in risk to operational fraud Reduction in risk to identity theft 17

18 Module 2 2 Identity Theft Red Flags under FACTA What are red flags? What are the red flags examples under FACTA? Module 2 Checkpoint Assessment 18

19 Module 2 Identity Theft Red Flags under FACTA What are the Red Flags Under FACTA? A red flag is defined as a pattern, practice, or specific activity that indicates the possible existence of identity theft. The red flag rules are designed to protect consumers or covered accounts from the most common types of identity fraud. While the following examples are a starting point for the identification of red flags, they are not intended to be an all inclusive list or checklist of what organizations can experience or classify as a red flag. 19

20 Module 2 Identity Theft Red Flags under FACTA What are the Identity Theft Red Flag Examples Under FACTA? FACTA has 26 examples of red flag activities or elements within Supplement A to Appendix J in the following 5 categories. Alerts, notifications or warnings from a consumer reporting agency Suspicious documents Suspicious personal identifying information Unusual use of, or suspicious activity related to, the covered account Notice from customers, victims of identity theft, law enforcement authorities or other persons regarding identity theft. 20

21 Module 2 Identity Theft Red Flags under FACTA What are the Identity Theft Red Flag Examples (#1-3) Under FACTA? Alerts, Notifications or Warnings from a Consumer Reporting Agency 1. A fraud or active duty alert is included with a consumer report 2. A consumer reporting agency provides a notice of credit freeze in response to a request for a consumer report. 3. A consumer reporting agency provides a notice of address discrepancy, as defined in 681.1(b) of this part. 21

22 Module 2 Identity Theft Red Flags under FACTA What are the Identity Theft Red Flag Examples (#4) Under FACTA? Alerts, Notifications or Warnings from a Consumer Reporting Agency - Continuation 4. 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) A recent and significant increase in the volume of inquiries; b) An unusual number of recently established credit relationships; c) A material change in the use of credit, especially with respect to recently established credit relationships; or d) An account that was closed for cause or identified for abuse of account privileges by a financial institution or creditor. 22

23 Module 2 Identity Theft Red Flags under FACTA What are the Identity Theft Red Flag Examples (#5-7) Under FACTA? Suspicious Documents 5. Documents provided for identification appear to have been altered or forged. 6. The photograph or physical description on the identification is not consistent with the appearance of the applicant or customer presenting the identification. 7. Other information on the identification is not consistent with information provided by the person opening a new covered account or customer presenting the identification. 23

24 Module 2 Identity Theft Red Flags under FACTA What are the Identity Theft Red Flag Examples (#8-9) Under FACTA? Suspicious Documents - Continuation 8. 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. 9. An application appears to have been altered or forged, or gives the appearance of having been destroyed and reassembled. 24

25 Module 2 Identity Theft Red Flags under FACTA What are the Identity Theft Red Flag Examples (#10-11) Under FACTA? Suspicious Personal Identifying Information 10. Personal identifying information provided is inconsistent when compared against external information sources used by the financial institution or creditor. For example: a. The address does not match any address in the consumer report; or b. The Social Security Number (SSN) has not been issued, or is listed on the Social Security Administration s Death Master File. 11. 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 25

26 Module 2 Identity Theft Red Flags under FACTA What are the Identity Theft Red Flag Examples (#12) Under FACTA? Suspicious Personal Identifying Information - Continuation 12. Personal identifying information provided is associated with known fraudulent activity as indicated by internal or thirdparty sources used by the financial institution or creditor. For example: a. The address on an application is the same as the address provided on a fraudulent application; or b. The phone number on an application is the same as the number provided on a fraudulent application 26

27 Module 2 Identity Theft Red Flags under FACTA What are the Identity Theft Red Flag Examples (#13) Under FACTA? Suspicious Personal Identifying Information Continuation 13. 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: a. The address on an application is fictitious, a mail drop, or a prison; or b. The phone number is invalid, or is associated with a pager or answering service 27

28 Module 2 Identity Theft Red Flags under FACTA What are the Identity Theft Red Flag Examples (#14-16) Under FACTA? Suspicious Personal Identifying Information Continuation 14. The social security number provided is the same as that submitted by other persons opening an account or other customers. 15. 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. 16. 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. 28

29 Module 2 Identity Theft Red Flags under FACTA What are the Identity Theft Red Flag Examples (#17-18) Under FACTA? Suspicious Personal Identifying Information - Continuation 17. Personal identifying information provided is not consistent with personal identifying information that is on file with the financial institution or creditor. 18. 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. 29

30 Module 2 Identity Theft Red Flags under FACTA What are the Identity Theft Red Flag Examples (#19-20) Under FACTA? Unusual Use of, or Suspicious Activity Related to the Covered Account 19. 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. 20. A new revolving credit account is used in a manner commonly associated with known patterns of fraud patterns. For example: a) 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 b) The customer fails to make the first payment or makes an initial payment but no subsequent payments. 30

31 Module 2 Identity Theft Red Flags under FACTA What are the Identity Theft Red Flag Examples (#21) Under FACTA? Unusual Use of, or Suspicious Activity Related to the Covered Account Continuation 21. A covered account is used in a manner that is not consistent with established patterns of activity on the account. There is, for example: a) Nonpayment when there is no history of late or missed payments; b) A material increase in the use of available credit; c) A material change in purchasing or spending patterns; d) A material change in electronic fund transfer patterns in connection with a deposit account; or e) A material change in telephone call patterns in connection with a cellular phone account. 31

32 Module 2 Identity Theft Red Flags under FACTA What are the identity theft red flag examples (#22-23) under FACTA? Unusual Use of, or Suspicious Activity Related to the Covered Account Continuation 22. 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). 23. Mail sent to the customer is returned repeatedly as undeliverable although transactions continue to be conducted in connection with the customer s covered account. 32

33 Module 2 Identity Theft Red Flags under FACTA What are the identity theft red flag examples (#24-25) under FACTA? Unusual Use of, or Suspicious Activity Related to the Covered Account Continuation 24. The financial institution or creditor is notified that the customer is not receiving paper account statements. 25. The financial institution or creditor is notified of unauthorized charges or transactions in connection with a customer s covered account. 33

34 Module 2 Identity Theft Red Flags under FACTA What are the identity theft red flag examples (#26) under FACTA? 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 26. 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. 34

35 Module 3 3 Development and implementation of an Identity Theft Red Flags Prevention Program What is Identity Theft? What are the core areas for developing and implementing an ID Theft Program? Module 3 Checkpoint Assessment 35

36 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program What is Identity Theft? Identity theft and identity fraud are terms used to refer to all types of crime in which someone wrongfully obtains and uses another individual s personal identifiable information or data in some way that involves fraud or deception. There are four common types of identity theft: Financial, Social Security, Medical and Criminal/Character. Identity theft is an international crime and not just about credit. An identity theft red flags prevention program is a mitigation strategy to reduce risks in this area. 36

37 Types of Identity Theft Organizations should identify, quantify and consider four main risk areas when assessing the extent of identity theft. Based on the extent and the combination of the given risk areas, the overall risk to a customer or customer data can increased as various risks elements are introduced Financial EXAMPLES OF IDENTITY THEFT RISKS Credit Card Fraud Debit Card Fraud Bank Account Fraud Brokerage Account Fraud Insider Theft Fraud Social Security Income Tax Fraud Employment Fraud Retirement Benefits Fraud Insider Theft Fraud Identity Theft Medical Health Care Services Fraud Online Prescription Fraud Insider Theft Fraud Criminal/Character Criminal Activity Fraud Identity Assumption Fraud Insider Theft Fraud Driver s License Fraud Commercial Service Fraud 37

38 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program What is Personal Identifiable Information (PII)? Personal Identifiable Information, also known as PII, is data or data points, a name or number that may be used, alone or in conjunction with any other information to identify a specific person, including: PII might include Name Social Security Number Date of Birth State or Government ID Card State or Government Driver s License Alien Registration Number Passport Number Employer ID Number Taxpayer ID Number 38

39 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program What is Personal Identifiable Information (PII)? Personal Identifiable Information, also known as PII, is data or data points, a name or number that may be used, alone or in conjunction with any other information to identify a specific person, including: PII might include Fingerprint, Voice Print Retina or Iris Image Other Physical Representation Electronic Identification Number Street address address Routing Code Credit or Debit Card with PIN Telecommunication identification or access device 39

40 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program There are two core areas of developing and implementing a FACTA identity theft red flags program as follows: Establishing a written program, including a program risk assessment and a program charter. Administering the program: Identifying relevant red flags, Detecting red flags, Responding to red flags, Preventing and mitigating identity theft, and Updating the program Establishing an identity theft training program Oversight of service provider arrangements Oversight of the development, implementation and administration of the program (i.e. Compliance Officer or Chief Identity Theft Officer Obtaining approval of the initial written program by the Board of Directors Address Discrepancy Rules Special rules for card issuers 40

41 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Establishing a written identity theft red flags prevention program, including a program risk assessment and a program charter. Each identity theft red flags prevention program should have a detailed written program designed to address the governance, implementation and maintenance of the program through policies, procedures and other arrangements that control reasonably foreseeable risks to customers or the safety and soundness of the financial institution or creditor from identity theft. As part of the written program, a charter or mission statement document should be developed and approval by the organization s board of directors. If the organization is a small or medium size business, the business owner or senior manager of the organization should approve charter or mission statement. 41

42 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Establishing a written identity theft red flags prevention program, including a program risk assessment and a program charter. A charter or mission statement document is customarily 2-4 pages and includes, but not limited to, the following items: Introduction Statement of Management Commitment Purpose of the Charter Scope of the Charter Executive Signoff Page 42

43 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Establishing a written identity theft red flags prevention program, including a program charter and a program risk assessment. Once the charter is developed, it is essential for the organization to identify a Chief Identity Theft Officer, Chief Compliance Officer, identity theft champion or a senior level manager to oversee the development, implementation and administration of the identity theft red flags prevention program. Many organization form a cross functional working committee with an identity theft champion or senior level manager as the team lead. Once the champion is chosen and a cross functional team is selected, it is incumbent to begin conducting a risk assessment and devising the administration to the program. 43

44 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program The Chief Identity Theft Officer or Chief Compliance Officer will need to research and obtain a variety of internal and external documents to complete the identity theft red flags risk assessment, to include, but not limited to: Business Continuity and Incident Response Plans Prior audits, inspections, policies or security vulnerability assessments (SVA) Gramm, Leach, Bliley Safeguard Procedures HIPPA Security Rule Procedures Current Data/Information Security Procedures/Policies Responsible Use Policies Code of Conduct/Ethics Policies Customer Identification Program Policies/Procedures 44

45 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program The Chief Identity Theft Officer or Chief Compliance Officer will need to research, obtain and leverage a variety of internal and external documents to complete the identity theft red flags risk assessment, to include, but not limited to: Prior audits, inspections, policies or security vulnerability assessments (SVA) Bank Secrecy Act Procedures Privacy Policy/Procedures Know Your Customer Procedures/Policies Current Corporate Anti-fraud Plans Current Corporate Investigation/Security Plans Any third party data security or fraud assessments within the last 24 months 45

46 Risk Assessment Documentation Identity Theft Risk Assessment Corporate Fraud Plan Information Security Privacy HIPPA GLB Usage Policies Security Plans Prior Audits, SVAs BCP Plans Incident Response Plans 46

47 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Once the necessary documents have been collected and reviewed, the Chief Identity Theft Officer (CITO) or Chief Compliance Officer (CCO) will need to conduct an identity theft red flags risk assessment. Prior to the identity theft red flags risk assessment, the CITO or CCO should develop and establish an identity theft red flags risk assessment team. The identity theft red flags risk assessment team should be comprised of team members with different skill sets and functional knowledge in corporate security, corporate fraud, corporate investigations, new account set-up, anti-money laundering, customer service, account servicing, information security, legal, privacy and information technology. 47

48 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Once the identity theft red flags risk assessment team has been established, the CITO and the assessment team will need to adopt or identify a risk assessment methodology for conducting the identity theft red flags risk assessment. 48

49 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program In general, the identity theft red flags risk assessment methodology might be a risk based, performance based or any type of quantitative process to measure risk. 49

50 Identity Theft Risk Assessment Methodology Asset Characterize Identify Supporting Infrastructure Threat Assessment Updating ID Theft Plan Action Plan For ID Theft Plan Asset Characterization: - Identification of red flags - Identification of Consequences - Identification of Critical Assets - Identification of Critical Interdependencies - Identification of Layers of Protection Risk Assessment Identity Theft Risk Assessment Elements Threat Assessment Identification of known threats to the company and industry Identification of suspected threats Identification of unknown threats Countermeasures Analysis Mitigation Strategy Risk Assessment Expected Affect of Risk on each Critical Asset Likelihood of Success of Attack Mitigation Strategy Detecting red flags Responding to red flags 50

51 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Now, the Chief Identity Theft Officer, Compliance Officer or Senior Manager has conducted research and leveraged internal/ external documents, established an identity theft red flags assessment team and developed an identity theft risk assessment methodology. How is the assessment conducted? By conducting an onsite survey or assessment using the following strategy? Review and evaluate policies/procedures for alerts, notifications or warnings from a consumer reporting agency for existing covered accounts and new accounts to include addresses, other customer account information and associated risks Review and evaluate policies/procedures setting up new accounts and servicing existing accounts Review and evaluate policies/procedures for suspicious documents for covered accounts 51

52 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program How is the assessment conducted? By conducting an onsite survey or assessment using the following strategy? Review and evaluate policies/procedures for suspicious personal identifiable information for covered accounts. Review and evaluate policies/procedures for unusual use of or suspicious activities related to covered accounts. Review and evaluate policies/procedures for notice from customers, victims of identity theft, law enforcement authorities or other persons regarding identity theft in connection with a covered account. 52

53 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program How is the assessment conducted? By conducting an onsite survey or assessment using the following strategy? Review and evaluate incident response policies/procedures for covered accounts. Review and evaluate privacy and information usage policies/ procedures for covered accounts. 53

54 Module 3 Development and implementation of an ID Theft Red Flags Prevention Program How is the assessment conducted? By conducting an onsite survey or assessment using the following strategy? Review and evaluate service provider, vendor, third party and subcontractor agreements or service level agreements in an effort to revise or implement reasonable policies and procedures designed to detect, prevent and mitigate the risk of identity theft to any covered accounts or covered account information accessed, stored, transferred or destroyed by service providers, vendors, third parties or subcontractors. Review and evaluate information technology/information security policies/procedures for collecting, accessing, storing, transferring and destroying information. 54

55 Identity Theft Risk to Data Organizations should also consider the data risks when assessing and evaluating the extent of identity theft to covered accounts or covered account information. Data Collection EXAMPLES OF RISKS TO DATA How is the data collected? What type of data is collected? Who is collecting the data What are the known threats to collecting data? Identity Theft Risk Assessment Data Storage Data Access & Data Transfer What data is stored? Where is the data stored? What safeguards are in place to protect data? What risks are known to storing data? How is data accessed? Who has access to the data? How is data transferred? Who has access to transferring data? What are the known risks to accessing or transferring data? Data Destruction How is data destroyed? Who destroys the data? What are the known risks to destroying data? 55

56 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Core areas of an ID Theft Program - Continuation Administering the program The program administration should include reasonable policies and procedures for detecting, identifying, preventing, responding and mitigating identity theft risks and relevant patterns, practices and forms of red flags signaling possible identity theft associated with the organization s business environment. The program administration should also included written verbiage regarding employee, contractor and vendor awareness training for identity theft, protection of personal identifiable information and data security. The training should identify frequency, methods, requirements and maintaining training records for employee, contractors and vendors. 56

57 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Core areas of an ID Theft Program Continuation Identifying Relevant Red Flags A critical element of developing and implementing an identity theft red flags program is identifying relevant red flags for covered accounts. The program must be tailored to the size and complexity, and the nature and scope of the financial institution or creditor s operations and must contain reasonable policies and procedures to: Identify red flags for covered accounts offer by the organization. Identify the methods used to opening new accounts and associated red flag risks. Identify the methods used to access covered accounts and associated red flag risks. 57

58 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Core areas of an ID Theft Program Continuation Identifying Relevant Red Flags A critical element of developing and implementing an identity theft red flags program is identifying relevant red flags for covered accounts. The program must be tailored to the size and complexity, and the nature and scope of the financial institution or creditor s operations and must contain reasonable policies and procedures to: Identify red flags for existing accounts. Identify the methods used to service existing accounts and associated red flag risks. Identify the methods used to access existing accounts and associated red flag risks. 58

59 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Core areas of an ID Theft Program Continuation Identifying Relevant Red Flags A critical element of developing and implementing an identity theft red flags program is identifying relevant red flags for covered accounts. The program must be tailored to the size and complexity, and the nature and scope of the financial institution or creditor s operations and must contain reasonable policies and procedures to: Identify any previous experiences with identity theft related to covered accounts. Identify any current or previous experience with identity theft related to your specific industry. 59

60 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Core areas of an ID Theft Program Continuation Detecting Red Flags A crucial element of developing and implementing an identity theft red flags program is detecting red flags for covered accounts. The program must be tailored to the size and complexity, and the nature and scope of the financial institution or creditor s operations and must contain reasonable policies and procedures to address the detection of red flags in connection with the opening of covered accounts and servicing existing account, such as: Detecting red flags for covered accounts offered by the organization. Detecting red flags by authenticating or monitoring covered accounts or activities for evidence of identity theft. Obtaining identifying information about, and verifying the identity of a person opening a covered or existing account. 60

61 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Core areas of an ID Theft Program Continuation Responding to Red Flags An essential element of developing and implementing an identity theft red flags program is responding red flags for covered accounts. The program must be tailored to the size and complexity, and the nature and scope of the financial institution or creditor s operations and must contain reasonable policies and procedures to address responding to red flags in connection with the opening of covered accounts and servicing existing accounts, such as: Responding appropriately to any red flags that are detected to prevent and mitigate identity theft 61

62 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Core areas of an ID Theft Program Continuation Preventing and Mitigating Identity Theft A critical element of developing and implementing an identity theft red flags program is preventing and mitigating identity risks. The program must be tailored to the size and complexity, and the nature and scope of the financial institution or creditor s operations and must contain reasonable policies and procedures to address the risk of identity theft posed to the customer or account, such as: Monitoring an account for evidence of identity theft Contacting the customer to validate activity or information Changing any passwords, security codes or other access to a customer s account 62

63 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Preventing and Mitigating Identity Theft A critical element of developing and implementing an identity theft red flags program is preventing and mitigating identity risks. The program must be tailored to the size and complexity, and the nature and scope of the financial institution or creditor s operations and must contain reasonable policies and procedures to address the risk of identity theft posed to the customer or account, such as : Re-opening an account with an new account number Not opening a new account Closing an existing account Notifying law enforcement Determine that no response is warranted 63

64 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Updating the Identity Theft Red Flags Program A vital element of developing and implementing an identity theft red flags program is updating the identity theft red flags program. The program must be tailored to the size and complexity, and the nature and scope of the financial institution or creditor s operations and must contain reasonable policies and procedures to address updating the program, such as : Updating the program periodically to reflect new developments and changes in the risk environment relating to identity theft. Annually reporting to the Board of Directors or senior management on the program effectiveness, service provider arrangements, significant identity theft incidents and recommendations for program changes. 64

65 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Core Areas of an ID Theft Program - Continuation Establishing a Identity Theft Training Program An essential element of developing and implementing an identity theft red flags program is establishing an identity theft training program. The program must be tailored to the size and complexity, and the nature and scope of the financial institution or creditor s operations and must contain reasonable policies and procedures to address identity theft training for implementing the program and continuous training for employees or contractors, vendors with responsibilities for opening, servicing or accessing covered accounts, such as : Identifying relevant red flags for covered accounts. Detecting Red Flags for covered accounts. Responding appropriately to any detected red flags. 65

66 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Establishing a Identity Theft Training Program A essential element of developing and implementing an identity theft red flags program is establishing an identity theft training program. The program must be tailored to the size and complexity, and the nature and scope of the financial institution or creditor s operations and must contain reasonable policies and procedures to address identity theft training for implementing the program and continuous training for employees or contractors, vendors with responsibilities for opening, servicing or accessing covered accounts, such as : Incident Response preparedness, contingency, recovery, and continuity planning for red flags events. Identity Theft Awareness for covered accounts. Social Engineering Scenarios for identity theft red flags. Handling customer accounts or personal identifying information. 66

67 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Establishing a Identity Theft Training Program A essential element of developing and implementing an identity theft red flags program is establishing an identity theft training program. The program must be tailored to the size and complexity, and the nature and scope of the financial institution or creditor s operations and must contain reasonable policies and procedures to address identity theft training for implementing the program and continuous training for employees or contractors, vendors with responsibilities for opening, servicing or accessing covered accounts, such as : Identity Theft red flags assessments and inspections. Knowledge of current identity theft threats and patterns. Assessment of identity theft red flags tests, drills and exercises. Review of the Identity Theft Prevention Program. 67

68 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Core Areas of an ID Theft Program - Continuation Oversight of Service Provider Arrangements A vital element of developing and implementing an identity theft red flags program is ensuring oversight of service providers, vendors, third parties and subcontractors who collect, access, store, transfer or destroy covered account information. The program must be tailored to the size and complexity, and the nature and scope of the financial institution or creditor s operations and must contain reasonable policies and procedures to ensure oversight of third parties, such as : Service Providers, vendors, third parties and subcontractors must comply by implementing reasonable policies and procedures designed to identify, detect, respond, prevent and mitigate the risk of identity theft to covered accounts or covered account information. 68

69 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Oversight of Administration of the Program An essential element of developing and implementing an identity theft red flags program is ensuring an appropriate committee or a designated employee at the level of senior management (i.e. Chief Identity Theft Officer, Chief Compliance Officer or Compliance Manager) has the oversight, development, implementation and administration of the program. The program strategy must be tailored to the size and complexity, and the nature and scope of the financial institution or creditor s operations and must contain reasonable policies and procedures to ensure program oversight, such as : Assigning of specific responsibilities for program implementation. Reviewing reports by staff and approving of material changes in the program. 69

70 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Oversight of Administration of the Program An essential element of developing and implementing an identity theft red flags program is ensuring an appropriate committee or a designated employee at the level of senior management (i.e. Chief Identity Theft Officer, Chief Compliance Officer or Compliance Manager) has the oversight, development, implementation and administration of the program. The program strategy must be tailored to the size and complexity, and the nature and scope of the financial institution or creditor s operations and must contain reasonable policies and procedures to ensure program oversight, such as : Reporting at least annually on compliance with the program. Facilitating the written program approval from the Board of Directors. 70

71 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Approval of the Written Program by Board of Directors A vital element of developing and implementing an identity theft red flags program is ensuring buy-in and approval of the written program by the board of directors. In order to ensure the identity theft red flags program is taken seriously and fully implemented, the written program must be approved by the organization s board of directors or an appropriate board committee. 71

72 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Address Discrepancy Rules The address discrepancy rules offer several examples of reasonable policies and procedures that the user (i.e. financial institution or creditor) of a consumer report can adopt as such. User can compare the information in the consumer report provided by the consumer reporting agency with information the user: Obtain and uses to verify the consumer s identity in accordance with the requirements of the customer identification program (CIP). Maintain in its own records, such as applications, change of address notifications or retained CIP source documents. Obtain information from a third party source. Verify the information in the consumer report provided by the consumer reporting agency with the consumer. 72

73 Module 3 Development and implementation of an ID Theft Red Flags Prevention Program Address Discrepancy Rules The address discrepancy rules also requires the user of consumer reports to develop and implement reasonable policies and procedures for furnishing an address for the consumer that the user has reasonably confirmed is accurate to the consumer reporting agency from whom it received the notice of address discrepancy. The user (i.e. financial institution or creditor) of the report needs to: Be able to form a reasonable belief the consumer report relates to the consumer about whom the user requested the report. Have established a continuing relationship wit the consumer. Regularly and in the ordinary course of business furnish information to the consumer reporting agency as part of the information it regularly furnishes for the reporting period in which it establishes a relationship with the consumer, from which the notice of address discrepancy relating to the consumer was obtained. 73

74 Module 3 Development and implementation of an ID Theft Red Flags Prevention Program Address Discrepancy Rules The user (i.e. financial institution or creditor) may reasonably confirm the address is accurate by: Verifying the address with the consumer about whom it has requested the report. Reviewing its own records to verify the address of the consumer. Verifying the address through third-party sources. Using other reasonable means. 74

75 Module 3 Development and Implementation of an ID Theft Red Flags Prevention Program Special Rules for Card Issuers A crucial element of developing and implementing an identity theft red flags program is special rules for card issuers. The program strategy must be tailored to the size and complexity, and the nature and scope of the financial institution or creditor s operations and must contain reasonable policies and procedures to address the validity of change of address notifications. 75

76 Module 4 4 Maintenance of an Identity Theft Red Flags Prevention Program What are the elements for maintaining the program? Module 4 Checkpoint Assessment? 76

77 Module 4 Maintenance of an ID Theft Red Flags Prevention Program Maintaining an Identity Theft Red Flags Program After establishing a program, It is essential to maintain the program maintenance for the identity theft red flags program. The program must be tailored to the size and complexity, and the nature and scope of the financial institution or creditor s operations and must contain reasonable policies and procedures to address maintaining the effectiveness and compliance of the program, such as : Developing and maintaining a documented strategy for identity theft metrics. Devising and documenting a self assessment strategy and methodology for evaluating the identity theft red flags program. Providing an annual identity theft awareness training for all employees and contractors. 77

78 Module 4 Maintenance of an ID Theft Red Flags Prevention Program Maintaining an Identity Theft Red Flags Program After establishing a program, It is essential to maintain the program maintenance for the identity theft red flags program. The program must be tailored to the size and complexity, and the nature and scope of the financial institution or creditor s operations and must contain reasonable policies and procedures to address maintaining the effectiveness and compliance of the program, such as : Providing continuous identity theft awareness to employees with identity theft responsibilities. Developing and devising a documented strategy and procedure for auditing the identity theft red flags program. Developing and devising a documented outreach strategy for customer care in the area of identity theft prevention and notification. 78

79 Module 4 Maintenance of an ID Theft Red Flags Prevention Program Maintaining an Identity Theft Red Flags Program After establishing a program, It is essential to maintain the program maintenance for the identity theft red flags program. The program must be tailored to the size and complexity, and the nature and scope of the financial institution or creditor s operations and must contain reasonable policies and procedures to address maintaining the effectiveness and compliance of the program, such as : Developing and devising a documented strategy and procedure for continuous monitoring of covered accounts to identify or reduce risks associated with identity theft. Developing and devising a documented strategy and procedure to test, drill and exercise the effectiveness of the identity theft red flags program. 79

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