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. |
As part of ICS's Identity Theft Risk Assessment, we
will:
- 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
|
Identity Theft Prevention Program:
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
|
(FACT Act Red Flags & Address Discrepancies)
