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#842118 - 10/25/07 02:09 PM FACTA Red Flage an Address Disc.
Tocomply Offline
Platinum Poster
Joined: Nov 2004
Posts: 650
In this final rule it refers to an Identify Theft Prevention Program. I have two questions. First, should I assume that there is to be a separate program titled Identify Theft Prevention Program or is this something that is to be built into the CIP? Second, isn't this just for lending areas?

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#842188 - 10/25/07 02:43 PM Re: FACTA Red Flage an Address Disc. Tocomply
ComplianceisOK Offline
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ComplianceisOK
Joined: Jan 2005
Posts: 167
Dickinson, ND
Identity theft affects all areas of the bank. According to the regulation I believe the Identity Theft Red Flag rules can be incorporated into your Information Security Program.

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#842209 - 10/25/07 03:00 PM Re: FACTA Red Flage an Address Disc. ComplianceisOK
Tocomply Offline
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Joined: Nov 2004
Posts: 650
Does anyone know what the regulators will look for? Must this be a program on it's own or can it be in the Info. Security program, AML/CIP or a program for FCRA or another policy?

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#842216 - 10/25/07 03:07 PM Re: FACTA Red Flage an Address Disc. Tocomply
Georgia Golfer Offline
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Georgia Golfer
Joined: Jun 2003
Posts: 415
1st Tee
I'm going to construct a seperate ID Theft program, but it will link to the Information Security program, BSA/AML & our FACTA policy and procedures.

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#844237 - 10/29/07 03:07 PM Re: FACTA Red Flage an Address Disc. Georgia Golfer
Compliance Girl Offline
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Compliance Girl
Joined: Aug 2007
Posts: 6
Pumpkin Capital
I sat in on a FACTA webinar 10/25/07 and the Speaker said he was pretty sure that this was going to beef up our CIP programs as well as BSA/AML. But he would be having an other seminar when he knows a little bit more.

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#844435 - 10/29/07 05:48 PM Re: FACTA Red Flage an Address Disc. Compliance Girl
KLouise Offline
100 Club
Joined: Dec 2005
Posts: 103
Missouri
Our ID Theft procedures are incorporated into our FACT Act policy. I did double check with our FDIC contact and was told that we DID NOT need a separate policy just for ID Theft.

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