I am curious if your bank has included business/commercial accounts and loans as covered accounts (meaning you have determined there is a reasonably foreseeable risk of ID theft) in your FACTA ID Theft Red Flags program.

1. Please indicate yes or no.

2. If yes, are you only including accounts/loans for sole proprietors and small business or are you also including accounts/loans for all business types (corporations, partnerships, etc.)

3. Also, if yes to item 1, have you identified red flags specific to the BUSINESS for these types of accounts? (if you could provide some examples that would be helpful as well)

Thank you for your assistance.

BUMP

It depends on your risk assessment:


(3) Covered account means:
(i) An account that a financial institution or creditor offers or maintains, primarily for personal, family, or household purposes, that involves or is designed to permit multiple payments or transactions, such as a credit card account, mortgage loan, automobile loan, margin account, cell phone account, utility account, checking account, or savings account; and
(ii) Any other account that the financial institution or creditor offers or maintains for which there is a reasonably foreseeable risk to customers or to the safety and soundness of the financial institution or creditor from identity theft, including financial, operational, compliance, reputation, or litigation risks

Thank you Randy, yes, I am aware of that. Trying to get a sense if other banks felt they should be considered covered based on their risk assessment.

We consider our commercial accounts covered accounts because there is a reasonably forseeable risk of fraud to their accounts.

Myscamper - Do you have any examples of a red flag for the business' identity being stolen that you would be willing to share?

Thanks.

If one considers an account takeover a form of ID theft (I do), then there's a pretty good track record being established with some of the fraudulent wire and ACH transfers being reported by Brian Krebs (Krebs on Security, at krebsonsecurity.com). Checks out his Small Business Victims section at http://krebsonsecurity.com/category/smallbizvictims/

We also include all business/commercial deposit accounts (checking & savings) to be covered per our risk assessment. Not loans. We feel that with all the documentation required and our underwriting there is minimal risk on the loan side. We included the business deposit accounts for the exact reason John mentioned above, Account Takeover. With the exposure of online banking that includes ACH & wires, we felt they should be included.

Examples of Red Flags would be pretty much the same as consumer, with increased online exposure of wires, ACH & RDC.

Thanks for the info John and ItNeverEnds.