Risk Assessment:

ICS will evaluate your institution's identity theft risks associated with the various covered accounts in conformance with the red flag risks identified within Supplement A to Appendix J of the Interagency Guidelines on Identity Theft Detection, Prevention, and Mitigation Guidelines under the authority of the FACT Act.

• Determine if the institution offers the various covered accounts
• Identify the risks associated with the covered accounts of the institution
• Evaluate whether the appropriate controls are in place for each covered account for each of the red flags identified in Appendix J and any other institution, identified red flags
• Interview key managers from appropriate business units

Based on the documentation review and management interviews, ICS will assess the current level of risk posed by each red flag to each covered account and current risk mitigation strategies already in place.  ICS will then prepare the Identity Theft Prevention Program to further mitigate the risks associated with the identified red flags.

The Program will be designed to:

• Identify relevant red flags
• Detect red flags when they occur
• Respond to red flags
• Handle address discrepancies reported by consumer reporting agencies
• Validate address changes when credit or debit, replacement or additional, cards are requested
• Ensure that the Program is updated and maintained