FCRA/FACT Act Red Flags

Financial institutions are required to have a written identity theft prevention program that is designed to detect, prevent and mitigate identity theft for covered accounts. An institution’s policies, procedures and processes should provide for:

  • Identifying red flags;
  • Detecting red flags;
  • Responding appropriately; and,
  • Ensure periodic updates.

Red Flags are addressed at length in the Interagency Guidelines on Identity Theft Detection, Prevention, and Mitigation (Appendix J) and should be considered and incorporated into an institution’s program.

Kevin explains more in the video.


Lending Resources!

Video Highlights:

  • A red flag is “a pattern, practice or specific activity that indicates the possible existence of identity theft.”
  • Five major categories of red flags are identified in Appendix J.
  • Red flags should be monitored for suspicious activity as part of your Bank Secrecy Act program.

Published
2023/08/28

 

Kevin Edwards

Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).

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