We are a foreign agency which does not take deposits. However, we do have the following accounts:

- Commercial Mortgage Accounts
- Contruction Loans
- Syndicated loans

Are all three accounts qualified for "Covered Account"?

I am in the early stage of writing a Red Flag Policy. Are there any good tools, references out there anyone would recommend?

Thank you in advance.

Those could be covered accounts. Consumer accounts accomodating multiple transactions are automatically covered, but other accounts such as these require you to do a risk assessment. You need to look at the risk of these accounts to determine whether identity theft is "reasonably foreseeable" in regard to them. If so, then they are covered accounts.