Red Flag Program Changes Needing Board Approval
Answered by BOL Gurus Mary Beth Guard and Jack Holzknecht Bios
Question: Please give an example of a material change to the program that would need Board approval.
Answer: You are required to update the program based on factors such as:
The experiences of the financial institution or creditor with identity theft;
Changes in methods of identity theft;
Changes in methods to detect, prevent, and mitigate identity theft;
Changes in the types of accounts that the financial institution or creditor offers or maintains; and
Changes in the business arrangements of the financial institution or creditor, including mergers, acquisitions, alliances, joint ventures, and service provider arrangements.
Such changes to the program should be approved by the Board or an appropriate committee of the Board.
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