Identity Theft Prevention Program - Policies and Procedures
Red Flags Rule and Address Discrepancies

by Jonathan Foxx
     President & Managing Director
     Lenders Compliance Group

On November 9, 2007 the OCC, FRB, FDIC, OTS, NCUA and FTC jointly issued the final rules and guidelines implementing section 114 of the Fair and Accurate Credit Transactions Act of 2003 (FACT Act) and final rules implementing section 315 of the FACT Act.

The rules implementing section 114 require financial institutions or creditors to develop and implement a written Identity Theft Prevention Program to detect, prevent and mitigate identity theft in connection with covered accounts and to establish policies and procedures to assess the validity of a change of address.

These rules and guidelines became effective January 1, 2008, and require financial institutions to comply by November 1, 2008. The Identity Theft Red Flag rules and guidelines apply to financial institutions and/or creditors such as: Banks, Credit Unions, Savings Associations, Mortgage Lenders, Mortgage Brokers, Auto Dealers, Phone Companies, Utility Companies, and Other Creditors.

Fortunately, you still have time to comply with the Red Flags Rule, which took effect on November 1, 2008. On July 29, 2009 the FTC extended its enforcement deadline from August 1, 2009 to November 1, 2009.

Our Identity Theft Prevention Program is the most comprehensive policy and procedure manual available. It is a 36-page, fully enumerated, indexed, and tabulated document! PLUS, the Program includes dynamic forms that permit us to customize your Identity Theft Prevention Program. Our off-site, due diligence review is included!

FEATURES OF OUR IDENTITY THEFT PREVENTION PROGRAM

Identity Theft Prevention Program – Policies and Procedures
Red Flags Rule and Address Discrepancies

          Tabulated Sections:

  • POLICIES AND PROCEDURES: 36-pages, enumerated and indexed
  • APPENDICES: 2 appendices for Red Flags and Alien Identification
  • FORMS: 16 forms used to implement the Program
  • FLOW CHARTS: for individuals and businesses
  • INCIDENTS REPORT
  • OVERRIDES
  • UPDATES
  • REVISION HISTORY
  • APPROVALS

 Identity Theft Prevention Program: $750

          Includes:

  • Complete Program and all supporting documents and sections
  • Due diligence, off-site review to customize the document
  • Binder
  • CD
  • Updates for 12 months
  • Hot Line Assistance for 12 months

Identity Theft Prevention Program - Policies and Procedures
$750 (tax + shipping)

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