Suggestions for New Company for Identifying Red Flags
Answered by BOL Gurus Mary Beth Guard and Jack Holzknecht Bios
Question: What suggestions do you have for a new company (less than one year in operation) that needs to identify the red flags, but has had minimal past experience?
Answer: You are supposed to determine appropriate red flags for your institution based on:
Your institutions prior incidents of identity theft;
Methods of identity theft that you have identified (based on industry research); and
Applicable supervisory guidance.
Since you have few prior incidents of identity theft you will rely most heavily on industry research and the red flags included in Supplement A to Appendix J of the red flag regulations.
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