Featured Article Federal Red Flag and Related Identity Theft Prevention Rules: Is Your Organization in Compliance?

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1 Featured Article Federal Red Flag and Related Identity Theft Prevention Rules: Is Your Organization in Compliance? Article contributed by: Nancy L. Perkins, Arnold & Porter LLP As of November 1, 2008, banks, credit unions, and other entities regulated by any of the federal banking agencies (the Federal Deposit Insurance Corporation, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Office of Thrift Supervision) or the National Credit Union Administration (NCUA) are required to have in place policies and procedures to prevent identity theft in connection with certain relationships with consumers. Under federal regulations adopted last year pursuant to the Fair and Accurate Credit Transactions Act of 2003 (FACTA), 1 virtually all of these entities must establish and implement written programs to identify and respond to red flags signaling a risk of identity theft, and may have additional obligations as well. The FACTA anti-identity theft regulations, which were jointly issued by the federal banking agencies and the NCUA, as well as the Federal Trade Commission (FTC or Commission), have three principal parts: (i) the Red Flags rule, which applies to financial institutions and creditors ; (ii) address change validation requirements, which apply to issuers of credit cards or debit cards; and (iii) address discrepancy investigation requirements, which apply to users of consumer reports. For all three parts, the agencies jointly set a compliance date of November 1, However, on October 22, 2008, the FTC announced that it was delaying its enforcement of the Red Flags rule until May 1, According to the Commission, many entities subject to its jurisdiction have been unaware that they are covered by the regulations in particular, many such entities have not understood that they are financial institutions or creditors within the meaning of the Red Flags portion of the rules. 2 But the FTC is not delaying enforcement of the other portions of the FACTA regulations, and its action does not affect enforcement by the banking agencies or the NCUA of any portion of the regulations. Many financial institutions have already taken steps to comply with the new FACTA rules. Those that have not should immediately assess their compliance obligations and proceed to develop the required policies and procedures. And, as specifically required by the regulations, entities that have established compliance policies must carefully review them on an ongoing basis to ensure that they are current and adequate in relation to all activities engaged in. This article discusses (1) the specific types of activities that determine who must comply with each of the three parts of the FACTA regulations, and (2) the various actions required by entities covered by each part. Red Flags Rule: Who is a Covered Financial Institution or a Creditor? A financial institution under FACTA includes 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 person that directly or indirectly holds a transaction account... belonging to a consumer. 3 A transaction account in this context means a deposit or account on which the depositor or account holder is permitted to make withdrawals by negotiable or transferable instrument, payment orders of withdrawal, telephone transfers, or other similar items for the purpose of making payments or transfers to third persons or others. 4 Typical types of transaction accounts are demand deposit accounts, negotiable order of withdrawal accounts, savings deposits subject to automatic transfers, and share draft accounts. 5 In essence, a transaction account... belonging to a consumer is any account holding a consumer s funds subject to withdrawal or transfer by the consumer. In addition to deposit accounts held by banks, savings associations, and credit unions, transaction accounts would include health insurance accounts such as Health Savings Accounts and Flexible Spending Accounts, and life insurance accounts such as Retained Asset Accounts. Thus, the holder of any such accounts is a financial institution for purposes of the FACTA regulations. A creditor is any person or entity 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 creditor who participates in the decision to extend,

2 renew, or continue credit. 6 Credit, in turn, is defined as the right granted by a creditor to a debtor to defer payment of debt or to incur debts and defer its payment or to purchase property or services and defer payment therefore. 7 An extension of credit may be made even if there is no finance charge and irrespective of the number of installments for repayment. Indeed, credit may be extended even if a customer does not defer payment, so long as the customer had the right to defer. The FACTA regulations expressly identify as creditors : banks, finance companies, mortgage brokers, automobile dealers, utility companies and telecommunications companies. The rules do not explicitly refer to members of other industries as creditors, but, to the extent that any entity provides a good or service without obtaining payment in advance or collecting payment at the point of sale or service, it is a creditor for purposes of the regulations. However, although the Red Flags rule applies to all financial institutions and creditors, its principal requirements affect only those financial institutions and creditors that maintain one or more covered accounts. A covered account in this context means a continuing relationship with one or more persons seeking to obtain a product or service from the financial institution or creditor that either (1) involves or is designed to permit multiple payments or transactions primarily for personal, family, or household purposes, or (2) has a business purpose but nevertheless presents a reasonably foreseeable risk to customers or the safety or soundness of the financial institution or creditor from identity theft. 8 Reasonably foreseeable risks from identity theft include (but are not limited to) financial, operational, compliance, reputation, or litigation risks to either the customer or the institution maintaining the account. 9 An account held for a small business or sole proprietor may present such risks if an individual s identifying information is used in connection with the account (in contrast to accounts of larger businesses where only a company s identifying information is used). If your organization meets FACtA s definition of either a financial institution or a creditor, the first step toward compliance with the Red Flags rule is assessing whether the organization offers or maintains any covered accounts. Unless that assessment reveals none of either type of covered account, your organization must establish an Identity theft Prevention Program (discussed further below). Address Change Rules: Who is an Issuer of a Credit or Debit Card? In general, it should not be difficult to determine if your organization is an issuer of credit cards or debit cards for purposes of the FACTA regulations. A credit card in this context is any card, plate, coupon book or other credit device existing for the purpose of obtaining money, property, labor, or services on credit. 10 A debit card is any card issued by a financial institution to a consumer for use in initiating an electronic fund transfer from the account of the consumer at such financial institution for the purpose of transferring money between accounts or obtaining money, property, labor, or services. 11 Cards designed specifically to enable consumers to defer payment for particular goods or services, such as the health care payment cards offered by GE money (the CareCredit card) or the Citi Health Card, are clearly credit cards under the regulations. However, some ambiguity exists with respect to stored value cards. Under the current regulations, payroll cards are debit cards but gift cards and other prepaid cards are not. 12 Thus, it would appear that Health Savings Account cards, such as the Wells Fargo Health Savings Account card and prepaid employee cards that draw on employers Health Reimbursement Accounts, are debit cards for purposes of the FACTA rules, while prepaid cards such as a Starbucks card, a prepaid phone card, and gift cards such as the Prepaid Healthcare Gift Card offered by Highmark, Inc. (which covers doctor s visits, pharmacy purchases, spa, gym, and wellness services), are not. This is an area that needs to be monitored, however, as new types of card payment options emerge and the federal regulators continue to evaluate the appropriate categorization of various card types. 13 Address Investigation Requirements: Who is a User of Consumer Reports? A user of consumer reports is any person or entity that orders credit reports or conducts background checks to determine a consumer s eligibility for purposes such as providing credit, insurance, or employment. 14 Typical examples are banks, insurance companies, landlords, and wide variety of employers. All such companies have address verification requirements under the FACTA rules. 2

3 Elements of the Red Flags Rule The fundamental requirement of the Red Flags rule is that every financial institution and creditor offering or maintaining one or more covered acc ounts must adopt a w ritten Identity Theft Prevention Program (Program) designed to detect, prevent, and mitigate identity theft in connection with the opening of a covered account or maintaining an existing covered account. From the outset, the financial institution must involve its board of directors, a committee thereof, or a designated employee at the senior management level in the Program, including its development, implementation, administration, and oversight. In connection with its Program, each financial institution or creditor must establish policies and procedures to: Identify relevant red flags for the covered accounts and incorporate those red flags into the Program; Detect red flags that have been incorporated into the Program; Respond appropriately to any red flags that are detected; and Ensure the Program (including the red flags determined to be relevant) is updated periodically, to reflect changes in risks to customers and to the safety and soundness of the financial institution or creditor from identity theft. A red flag for purposes of the rule is a pattern, practice, or specific activity that indicates the possible existence of identity theft. Every Program should include relevant red flags from the following five categories, as appropriate: Alerts, notifications, or other warnings received from consumer reporting agencies or service providers, such as fraud detection services; the presentation of suspicious documents; the unusual use of, or other suspicious activity related to, a covered account, and 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. The rule provides a non-exclusive list of 26 examples of red flags within these five categories, which each financial institution or creditor should consider including in its Program. Although the 26 examples do not specifically refer to medical information, as the promulgating agencies explained, creditors in the health care field may be at risk of medical identity theft (i.e., identity theft for the purpose of obtaining medical services) and, therefore, must identify red flags that reflect this risk. 15 The Program s policies and procedures on detecting red flags should include measures such as obtaining identifying information about, and verifying the identity of, a person opening a covered account; and, in the case of existing covered accounts, authenticating customers, monitoring transactions, and verifying the validity of change of address requests. Once a red flag has been detected, a financial institution or creditor must take appropriate steps to respond, taking into account aggravating factors that may heighten the risk of identity theft, such as a data security breach or notice that a customer has been fraudulently induced to provide account-related information to a person likely to misuse the data. Appropriate responses might include, for example: (i) monitoring a covered account for evidence of identity theft; (ii) contacting the customer; (iii) changing any passwords, security codes, or other security devices that permit access to a covered account; (iv) reopening a covered account with a new account number; (v) not opening a new covered account; (vi) closing an existing covered account; (vii) not attempting to collect on a covered account or not selling a covered account to a debt collector; (viii) notifying law enforcement; or (ix) determining that no response is warranted under the particular circumstances. the presentation of suspicious personal identifying information, such as a suspicious address change; To ensure that its Program is appropriate and effective on an ongoing basis, each financial institution or creditor must periodically update it in the event of changes in riskrelated factors, such as changes in known methods of identity theft or methods to detect, prevent, or mitigate 3

4 identity theft, or changes in the types of covered accounts offered or maintained. The financial institution or creditor also must train its staff responsible for covered accounts and must exercise appropriate and effective oversight of any service providers assisting in the opening or maintenance of the accounts. And the personnel responsible for administering the Program must provide a compliance report at least annually to the entity s board of directors or designated senior management employee. In developing and administering its Program, each financial institution or creditor should also bear in mind certain other, related legal requirements, such as the Fair Credit Reporting Act s limitations on extending credit in the event of a detection of a fraud or active duty alert, 16 the requirement for furnishers of information to consumer reporting agencies to correct or update inaccurate or incomplete information, 17 and, for those subject to the federal anti-money laundering regulations, the filing of Suspicious Activity Reports in connection with customer accounts. 18 Address Change Requirements for Issuers of Credit or Debit Cards The FACTA address change rules applicable to credit card and debit card issuers are principally designed to protect these issuers and their cardholders from a typical practice of identity thieves: using cardholder information to request that an additional card be sent to an address other than the address of the cardholder. By that practice, identity thieves are able to obtain and use a new card without the knowledge of the true cardholder at least until the cardholder receives his/her next billing statement, potentially making substantial unauthorized purchases. To prevent such fraudulent use of a cardholder s identity, the FACTA rules require issuers to establish policies and procedures to assess the validity of a notice of change-ofaddress for cardholder s account whenever, within at least the 30-day period after receipt of such notice, the issuer receives a request for an additional card on the same account. When such a situation arises, the issuer may not issue the requested additional card until it has either assessed the validity of the address change pursuant to its established policies and procedures, or notified the cardholder of the request for the additional card and provided the cardholder a reasonable means of reporting incorrect address changes. If the issuer chooses the latter option, its notification to the cardholder must be clear and conspicuous, separate from regular correspondence with the cardholder, and sent either to the cardholder s former address or by another means previously agreed to by the cardholder. Address Verification Rules for Users of Consumer Reports The FACTA regulations requirements for address verification by users of consumer reports apply when a consumer reporting agency from which the user obtained a consumer report notifies the user of a substantial difference between the address the user provided to request the report and the address(es) in the credit reporting agency s file. To respond to such a notice of address discrepancy, each user must develop and implement policies and procedures through which it can form a reasonable belief that the consumer report it obtained relates to the relevant consumer. Such policies and procedures might involve, for example, comparing the information in the consumer report with information on the consumer the user maintains on file or can obtain from one or more reliable third-party sources, or contacting the consumer directly to verify the information in the consumer report. Users also must have policies and procedures for furnishing to the relevant consumer reporting agency an address for the consumer that the user has reasonably confirmed to be accurate. The requirement to furnish such information, however, is triggered only when the user establishes a continuing relationship with the consumer and regularly and in the ordinary course of business furnishes information to that consumer reporting agency. Appropriate Action Plans: Immediate and Ongoing Entities regulated by any of the federal banking agencies or the NCUA should be aware that these federal agencies will be including assessments of compliance with the FACTA identity theft regulations in their regular examinations of individual institutions. The agencies are developing specific guidance for their examiners to evaluate the adequacy of each regulated entity s antiidentity theft programs, focusing on key vulnerabilities that should be probed in the process of a regulatory exam. The Office of Thrift Supervision has already updated its pertinent examination handbook to include such guidance, 19 and the other agencies are expected soon to follow suit. Federally regulated financial institutions should be prepared to deal with examiner questions regarding compliance with all applicable portions of the rules, including but not limited to the required Red Flags 4

5 Identity theft Prevention Program, at their next scheduled examination. Input from legal counsel is critical at each stage in the compliance process, both to ensure accurate analysis of the applicability of the rules and to assess the adequacy of particular compliance measures. The consequences are significant: although there is no private right of action to enforce the regulations, violators are subject to civil penalties and, even in the private litigation context, the standards prescribed by the regulations could be cited as a basis to determine liability under generally applicable state consumer protection laws. Nancy L. Perkins is a counsel in the Washington, D.C. law firm of Arnold & Porter LLP. Ms. Perkins regularly advises clients on federal and state requirements for privacy and security of medical, financial, and electronic data. She has particular expertise in the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, as amended by the Fair and Accurate Credit Transactions Act, the Health Insurance Portability and Accountability Act, and these statutes implementing regulations. She also has an extensive background in international law and advises clients on the rapidly developing framework for global protection of data privacy and security. Ms. Perkins can be reached at cover prepaid card products under that definition in the future. See id. 14 A consumer report in this context includes any written, oral or other communication bearing on a consumer s credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics or mode of living that is or may be used or collected to establish a consumer s eligibility for credit, insurance, or employment, or for another purpose permissible under the federal Fair Credit Reporting Act. 15 U.S.C a(d)(1) Fed. Reg. at See 15 U.S.C. 1681c-1(h). 17 See 15 U.S.C. 1681s See 31 U.S.C. 5318(g). 19 Office of Thrift Supervision, Regulatory Bulletin (oct. 24, 2008), available at 1 Public Law , 117 Stat (Dec. 4, 2003). The FACTA regulations were published in final form in November See Identity Theft Red Flags and Address Discrepancies Under the Fair and Accurate Credit Transactions Act of 2003, 72 Fed. Reg (Nov. 9, 2007) (codified at 12 C.F.R. Parts 41, 222, 334, 571, 717; 16 C.F.R. Part 681). For simplicity, citations herein are to the codified sections of the Federal Deposit Insurance Corporation regulations. 2 See FTC Enforcement Policy: Identity Theft Red Flags Rule, 16 C.F.R , available at 10/ idtheftredflagsrule.pdf U.S.C a(t) (emphasis added) U.S.C. 461 (b)(1 )(C). 5 Id U.S.C a(e) U.S.C a(d) (emphasis added) C.F.R (b)(3) C.F.R (b)(3)(ii) U.S.C. 1602(k) U.S.C. 1681a(r)(3). 12 Id. 13 Indeed, the Board of Governors for the Federal Reserve System only recently defined payroll cards as accounts for Electronic Funds Transfer Act purposes, and may also elect to 5

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