There has been a lot of buzz about ID theft and the Red Flags regulations in BOL's Bankers' Threads. What are other bankers' questions, comments and thoughts on these topics? We've selected some key Threads from those conversations.
Definitions ID Theft
Part of every compliance officer's effort to deal with regulatory requirements is the need for a basic understanding of defined terms. "Identity theft" is a term at the very center of the Identity Theft Red Flags and Address Discrepancy regulations. Embezzlement, Fraud or ID Theft?
Another thread starts with a question about applicability of the ID Theft Red Flag rules to an insurance agency subsidiary, and develops into a broader discussion of subsidiaries, divisions, and covered accounts. Red Flag Rules and Insurance Agency Subsidiaries
Address Changes and Credit/Debit Cards Verifying Address Changes
Although managing address changes has long been a hot topic among bankers, the subject got new urgency when it was given legal and regulatory legitimacy in the FACT Act and the new FCRA regulations.
Threads users attempted to sort out various methods for verifying a card customer's request for an address change. Validating Address Changes
ID Theft Risk Analysis Access Method
One of the factors to consider in the Risk Analysis of a bank's products and services is how the product is accessed by customers. Internet and Telephone Banking
One access method that you might have missed is electronic access via the Automated Clearing House (ACH). ACH Identity Theft
Accounts Covered
Mention "Identity Theft," and the first types of accounts that come to mind are those of consumers. Yet the Identity Theft Red Flag regulation's reach is broader. Red Flag Compliance and Commercial Loans
It can be tempting to rely on familiar definitions. However, when a common word like "account" gets used in a regulation, failing to recognize the correct definition can result in an incomplete compliance program. Safe Deposit as a Covered Account
Address Discrepancies
A process for handling address discrepancies that appear in credit reports is mandated by new §___.82 (Duties of Users Regarding Address Discrepancies) of the Agencies' Fair Credit Reporting Act regulations. Applicability of those rules to bank operations has been a popular topic in Bankers' Threads. HR, Employees and Red Flags
Monitoring for ID Theft
One result of banks' analysis of products and services is a realization that some form of transaction monitoring may be needed as part of its Identity Theft Prevention Program. That may mean monitoring of products where no monitoring has been done to date. Monitoring HELOC Account Activity
Planning for Examinations
For many bankers who will be conducting examinations is as important as the regulatory requirements themselves. Will reviews of a bank's Identity Theft Prevention Program be included in Safety and Soundness exams, or will they be done by Compliance or IT examiners? Red Flags and IT Audit?
Overlapping Requirements Board Involvement
One provision of the new regulations is a requirement for board or board committee involvement in oversight of a bank's Identity Theft Prevention Program. Bankers' Threads users discussed this requirement, too. Can Program reporting be combined with other reports? Board Reporting
ID Theft Prevention and CIP
Identity is obviously a central factor in both the Customer Identification Program requirements in Treasury regulations and in the FACT Act ID Theft Red Flags regulations. Can a bank's existing CIP procedures be used for verifying identification under the Red Flags rules? CIP and Identity Theft Prevention Programs
Other Threads
When discussing plans for its ID Theft Prevention Program, a bank began thinking about offering ID theft insurance. That was the genesis of a Thread prompting a cautionary comment. ID Theft Insurance
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