Concluding this round of guidance for the Red Flags Rule in effect as of December 31, 2010, here are the 26 Red Flags identified by the FTC–the government agency charged with enforcing compliance with this latest legislation related to identity theft prevention.
1. A fraud alert included with a consumer report.
2. Notice of a credit freeze in response to a request for a consumer report.
3. A consumer reporting agency providing a notice of address discrepancy.
4. Unusual credit activity, such as an increased number of accounts or inquiries.
5. Documents provided for identification appearing altered or forged.
6. Photograph on ID inconsistent with appearance of customer.
7. Information on ID inconsistent with information provided by person opening account.
8. Information on ID, such as signature, inconsistent with information on file at financial institution.
9. Application appearing forged or altered or destroyed and reassembled.
10. Information on ID not matching any address in the consumer report, Social Security number has not been issued or appears on the Social Security Administration’s Death Master File, a file of information associated with Social Security numbers of those who are deceased.
11. Lack of correlation between Social Security number range and date of birth.
12. Personal identifying information associated with known fraud activity.
13. Suspicious addresses supplied, such as a mail drop or prison, or phone numbers associated with pagers or answering service.
14. Social Security number provided matching that submitted by another person opening an account or other customers.
15. An address or phone number matching that supplied by a large number of applicants.
16. The person opening the account unable to supply identifying information in response to notification that the application is incomplete.
17. Personal information inconsistent with information already on file at financial institution or creditor.
18. Person opening account or customer unable to correctly answer challenge questions.
19. Shortly after change of address, creditor receiving request for additional users of account.
20. Most of available credit used for cash advances, jewelry or electronics, plus customer fails to make first payment.
21. Drastic change in payment patterns, use of available credit or spending patterns.
22. An account that has been inactive for a lengthy time suddenly exhibiting unusual activity.
23. Mail sent to customer repeatedly returned as undeliverable despite ongoing transactions on active account.
24. Financial institution or creditor notified that customer is not receiving paper account statements.
25. Financial institution or creditor notified of unauthorized charges or transactions on customer’s account.
26. Financial institution or creditor notified that it has opened a fraudulent account for a person engaged in identity theft.
It’s a long, but not exhaustive list. The most important thing for companies is to have a written Red Flags policy to demonstrate due diligence. We will all be working together in the spirit of the law–helping head off the high cost of identity on individuals, companies, and the county at large. For more information visit www.hvshred.com