Monitoring Expectations
Answered by BOL Gurus Mary Beth Guard and Jack Holzknecht Bios
Question: I would like to know what your sense of any monitoring expectation that the regulators have as it relates to identity theft. For example, the Federal register stated that monitoring might be appropriate as a measure to preventing and mitigating identity theft. Do you sense that the banking industry will adopt monitoring similar to monitoring required under anti-money laundering regulations? Any guidance you can offer for this issue would be helpful to me.
Answer: The regulations and guidelines anticipate that monitoring requirements will be part of the Identity Theft Prevention program. For example Red Flag #21 (Supplement A to Appendix J) requires monitoring of activity on existing accounts. This monitoring is similar to the AML monitoring requirements.
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