Transcript Identity Theft Red Flags and Address Discrepancies Joint

Identity Theft Red Flags
and Address
Discrepancies
Joint Notice of Proposed
Rulemaking
October 12, 2006
AIIM of Wisconsin
ID Theft Red Flags & Address
Discrepancies
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FIL-64-2006 & other agency issuances
FACTA – Sections 114 & 315
Notice of Proposed Rule Making - comment
period closed Sept. 18
36 comments – FDIC; approximately equal
number for the other agencies
ID Theft Red Flags & Address
Discrepancies
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Written ID Theft Prevention Program – at least for FIs
Appendix to the Regulation – has 31 enumerated ID Theft
Red Flags (RF) > program to respond to each and systems in
place to address; ie credit report with fraud alert > the person
may/not be the owner of the account => system in place to
validate the owner or pretender
if RF kicked out – must demonstrate/prove not applicable
address change > within 30 days; not to issue the card unless
confirms that someone is authentic. To avoid mail re-direct
scam. [mandated by statute]
Address discrepancies – by credit report vs the other address
shown. FI must take additional steps to validate the ID of
owner
FI must report back to credit reporting agency and reasons
believed the address is valid
ID Theft Red Flags & Address
Discrepancies
ID Theft Red Flags & Address
Discrepancies
ID Theft Red Flags & Address
Discrepancies
Thank You!
L. Bruce Finn
[email protected]
IT Examiner
Division of Supervision and Consumer Protection,
Chicago Region
Questions?