Including Red Flags as Part of the Identity Theft Program
Answered by BOL Gurus Mary Beth Guard and Jack Holzknecht Bios
Question: If the bank does not have a program in place to detect or monitor some of the red flags (for example, #21 discusses inconsistent patterns of activity), will we still be required to include the red flag as part of our identity theft program?
Answer: The Red Flags listed in Appendix J Supplement A are examples. You are not required to include all of the examples in your Program. You get to decide what is appropriate for your institution - but be prepared to defend your exclusions. We encourage you to be ready to explain why a particular example is not an appropriate Red Flag for your institution.
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