include reasonable policies and procedures to: 1. All employees working with covered accounts will be familiar with the Red Flag Rules. on (date). Accordingly, the Red Flags Rule provides guidance as to what should be considered when crafting policies and procedures to identify Red Flags … 5. If there are changes in this policy, the Red Flags Officer will train Staff, as appropriate, regarding those changes. 2. Policy Template – Red Flag Identity Theft Prevention and Detection Procedures Policy Admission and Accounts Receivable staff, or other staff as deemed appropriate, will take reasonable steps to identify, verify and mitigate possible identity theft that may occur during the Detect red flags that have been incorporated into the Program; All red flag responses should also be kept in a dealership file to be used to maintain and update the program. Document all red flag responses and keep them in the customer file. 3 For example, if a customer has to provide some form of identification to open an account with your company, an ID that doesn’t look genuine is a “red flag” for your business. The Red Flags Rule recognizes that a “one size fits all” approach to designing and implementing a compliant Program would not promote the objectives of the rule. Detail a plan to update the program periodically. Red Flags • The Federal Trade Commission has identified “26 Red Flags” to be used as a . name] will (1) identify, (2) detect and (3) respond to “red flags.” A “red flag” as defined by this policy includes a pattern, practice, or specific account or record activity that indicates possible identity theft. Issue a letter to the consumer that describes the Red Flag and a statement that informs the applicant that, due to the cancellation of the application, the lender is not responsible for further steps that may be required to correct or mitigate the discrepant data Sample Pages Our Program Coordinator We have appointed as the Program Coordinator of our Dealership’s Identity Theft Red Flags and Notices of Address Discrepancy Policy Program. when a Red Flag is detected: 1. On Wednesday, May 13, 2009, the FTC released a "template" identity theft prevention program (.pdf) to guide businesses subject to a "low risk" of identity theft through the process of complying with federal Red Flags Rules. guide for drafting an internal policy • The FTC list is not to be used as a “checklist” - companies must list sources and examples that are specific to their business model • 1. Red Flags Identity Theft Plan Policy Manual . It is the policy of Nova Southeastern University to comply with the FTC Red Flag Rules. Identify relevant red flags for covered accounts it offers or maintains and incorporate those red flags into the program; 2. The FTC template was first announced on May 1, 2009 when the agency postponed enforcement of the general purpose Red Flags Rules until August More The Red Flags Officer will train new Staff within two weeks of their joining the Practice as listed above. Red Flags are suspicious patterns or practices, or specific activities that indicate the possibility of identity theft. Complete the Red Flag Checklist. The Identity Theft Red Flags & Address Discrepancies Final Rule under the FACT Act, known as the Red Flags Rule, mandates that all mortgage lenders and brokers must have a written identity theft plan to detect, prevent and mitigate identity theft in connection with certain financial accounts. 6. E. The Practice will have business associates sign Red Flag Agreements. 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