If in the process of pulling a credit report you identify a consumer with a fraud alert and this consumer has multiple relationships with your institution, are you communicating this information to these other areas?

In our situation, only lending areas will identify these consumers, as the deposit side does not receive credit report information. The deposit folks feel no need for this information saying existing procedures are adequate to protect consumer. Of course I don’t agree but have not been able to convince them that this information needs to be communicated as extra security measures may be necessary to protect the consumer and the bank.

Anyone else encountering this problem and if so, how are you dealing with it?

Thanks much --

We will be flagging the customer's profile, so that all areas can see that there is a fraud alert on them and be more cautious.

Devilish -- Are you putting an expiration date on your action?

BUMP, BUMP!

What are you doing on the deposit side of the bank if you are aware a deposit customer has placed a fraud alert on his/her credit report??? The only thing I can think of, CIP even though an exisiting customer.

What am I missing?

We are exploring placing a system alert. Unfortunately that does not mean another department staffer is guaranteed to "see" the system alert. We think it is a reasonable step to take although not perfect.

I would emphasize that FACTA has more to do with Identity Theft than credit reporting. Part 603(q)(3) defines identity theft as a fraud committed using the identifying information of another person. When a customer claims they did not write a check or make a certain ATM transaction, that is Identity Theft. As such your deposit area must adhere to the rules in FACTA.

The President and Senior VP's in our institution formed a group called FROG (fraud resource organizing group) to implement FACTA procedures bank wide. Our plans will have any employee who learns of ID Theft Alert by any means to report it to one person. This person will verify that all accounts upon which the affected individual signs, have been flagged with our internal Theft Alert. That alert requires extra identification before cashing a check, changing an address, increasing loan limits, etc. Both the loan and deposit sides of the bank are affected in proving we are dealing with the customer and not the thief.