FCRA - Red Flag Account Warnings
Sarah Scott, CRCM and VP Compliance and CRA at County Bank in Merced, CA, has provided this Excel worksheet to assist bankers in managing red flag warnings. The PDF attachment is from only one tab in this eight tab worksheet. It is intended to demonstrate the content that is included on:
- credit card accounts
- mortgage loans
- auto loans
- single payment loans
- margin accounts
- checking accounts and
- savings accounts
- The remaining tab is an account overview.
The first page of the document is an overview of accounts which could be subject to identity theft, based on those identified in the regulation. Each bank would of course need to tailor accounts to what it offers by adding to or deleting accounts from the list. The first page includes an area to rate the risks for each account based on the criteria in the regulations. The subsequent pages (tabs) list each type of account identified on the first page, and list the red flags identified in the regulation, with spaces for detection methods and mitigation, as they are required to be analyzed by the regulation. If a red flag is not applicable, it could be marked as such, and other institution-specific red flags added at the bottom for analysis.
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