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#974962 - 06/13/08 05:41 PM Handling the ITPP Red Flags
Many Hats Offline
Platinum Poster
Joined: May 2008
Posts: 915
Orlando, FL
As we look at the list of red flags (and assuming that our bank has no current policy or procedure in place to address the various red flags), is there a resouce out there to give us guidance on how we SHOULD be addressing them?

I am filling out our list and although I can indicate what I THINK we should do if, for example, we pull a credit report and there is a fraud alert, but I want to know the best practice for addressing each of them.

Is anyone else having trouble with this? Or am I over-thinking it?

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#975303 - 06/13/08 11:44 PM Re: Handling the ITPP Red Flags Many Hats
Compliance4521 Offline
Platinum Poster
Compliance4521
Joined: Jan 2007
Posts: 533
Washington
We plan on rolling up many of the 'responses' into procedures. For example: For the red flags that are following under CRA section, we will have a response that indicates: Follow the Credit Alert procedures. It iw within those credit alert procedures we will identify what to do based upon the alert, and research found.

We are doing the same concept with anything related to 'mail or address' red flags.

Does this make sense? Thoughts?

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#976635 - 06/17/08 06:52 PM Re: Handling the ITPP Red Flags Compliance4521
Many Hats Offline
Platinum Poster
Joined: May 2008
Posts: 915
Orlando, FL
I am working on our responses to the red flags from the standpoint of the loan origination process.

For example, if a credit report is pulled and we notice that there is a credit freeze.....what should we do? It seems like they want all banks to come up with their own idea of how it should be handled, but HOW DO THEY WANT IT TO BE HANDLED is the question. If I see a credit freeze, I would call up the customer and ask them about it. I am sure there's probably a better answer and I'd just like to see some examples of potential responses.

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#976707 - 06/17/08 07:37 PM Re: Handling the ITPP Red Flags Many Hats
Ted Dreyer Offline
Diamond Poster
Ted Dreyer
Joined: Apr 2001
Posts: 2,245
Credit freezes are usually from state law, so you might want to look at what your state law says as far as handling them.

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