About a Separate Identity Theft Prevention Program
Answered by BOL Gurus Mary Beth Guard and Jack Holzknecht Bios
Question: Please clarify separate identity theft prevention program; can't it be incorporated into the bank's GLBA Information Security Program?
Answer: The regulations require an Identity Theft Prevention program. The regulations also clarify that existing policies and procedures may be incorporated into the Program, as appropriate. The regulations do not provide that the Program can be incorporated into a different policy or procedure.
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