I know there is a risk assessment piece to the Red Flags provisions, but I was what other banks were doing with regard to account opening procedures.

For example, right now we pull a Chex Systems for deposit accounts and then have the account officer keep their eyes out for cusotmers who live out of the area and are opening account or other info that may not make sense.

However, I'm wondering if we are going to have to go with purchasing a more sophiscated Chex Systems report that has more fraud indicators associated with it (i.e. looking at the address location, giving other names the SSN is tied to, etc.) when we open new accounts?

Do you think these more sophisticated reports are going to be necessary to comply with the regulations?

I know its based on my banks risk, but sometimes regulators forget about that and start looking for a standard thing...I just want to be prepared and start looking at vendors to help us with this.