Missouri Guide to Complying with the Red Flags Rule under FCRA and FACTA

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Multi-State
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US-FCRA-02
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PDF
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This guide has two parts: Part A to help you determine whether your business or organization is at low risk, and Part B to help you design your written Identity Theft Prevention Program if your business is in the low risk category.


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FAQ

Institutions are required to have a written identity theft prevention program (ITPP) to govern their organization and protect their consumers. What's a red flag? The FTC defines a red flag as a pattern, practice or specific activity that indicates the possible existence of identity theft.

This ITPP addresses 1) identifying relevant identity theft Red Flags for our firm, 2) detecting those Red Flags, 3) responding appropriately to any that are detected to prevent and mitigate identity theft, and 4) updating our ITPP periodically to reflect changes in risks.

A red flag is a pattern, practice, or activity that indicates a possibility of identity theft. These flags produce a three digit score (0-999) that calculates the customer's fraud risk through the credit report. A higher score indicates a lower risk of identity fraud.

The Red Flags Rule requires organizations to implement a written identity theft prevention program to help them identify any of the relevant ?red flags? that indicate identity theft in daily operations. The Rule also offers steps to help prevent the crime and to mitigate its damage.

Signs of fraud include an email address that cannot be verified, an email address that the victim has no record of using in the past, or the same email address used on several new account applications.

The Federal Trade Commission (FTC) enforces the Red Flags Rule with several other agencies.

The Red Flags Rule requires specified firms to create a written Identity Theft Prevention Program (ITPP) designed to identify, detect and respond to ?red flags??patterns, practices or specific activities?that could indicate identity theft.

The Red Flags Rule requires that each "financial institution" or "creditor"?which includes most securities firms?implement a written program to detect, prevent and mitigate identity theft in connection with the opening or maintenance of "covered accounts." These include consumer accounts that permit multiple payments ...

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Missouri Guide to Complying with the Red Flags Rule under FCRA and FACTA