(A) All employees responsible for or involved in the process of opening a covered account, restoring a covered account or accepting payment for a covered account shall check for red flags as indicators of possible identity theft.
(B) Such red flags shall include, but not be limited to:
(1) Alerts from consumer reporting agencies, fraud detection agencies or service providers. Examples of such alerts are:
(a) A fraud or active duty alert that is included with a consumer report;
(b) A notice of credit freeze in response to a request for a consumer report;
(c) A notice of address discrepancy provided by a consumer reporting agency; and
(d) Indications of a pattern of activity in a consumer report that is inconsistent with the history and usual pattern of activity of an applicant or customer, such as:
1. A recent and significant increase in the volume of inquiries;
2. An unusual number of recently established credit relationships;
3. A material change in the use of credit, especially with respect to recently established credit relationships; or
4. An account that was closed for cause or identified for abuse of account privileges by a financial institution or creditor.
(2) Suspicious documents. Examples of suspicious documents include:
(a) Documents provided for identification that appear to be altered or forged;
(b) Identification on which the photograph or physical description is inconsistent with the appearance of the applicant or customer;
(c) Identification on which the information is inconsistent with information provided by the applicant or customer;
(d) Identification on which the information is inconsistent with readily accessible information that is on file, such as a signature card or a recent check; or
(e) An application that appears to have been altered or forged, or appears to have been destroyed and reassembled.
(3) Suspicious personal identifying information. Examples include:
(a) Personal identifying information that is inconsistent with external information sources used by the financial institution or creditor. For example:
1. The address does not match any address in the consumer report; or
2. The Social Security Number (SSN) has not been issued, or is listed on the Social Security Administration’s Death Master File.
(b) Personal identifying information provided by the customer is not consistent with other personal identifying information provided by the customer, such as a lack of correlation between the SSN range and date of birth.
(c) Personal identifying information, a phone number or address is associated with known fraudulent applications or activities as indicated by internal or third-party sources used by the financial institution or creditor.
(d) Other information provided, such as fictitious mailing address, mail drop addresses, jail addresses, invalid phone numbers, pager numbers or answering services, is associated with fraudulent activity.
(e) The SSN provided is the same as that submitted by other applicants or customers.
(f) The address or telephone number provided is the same or similar to the account number or telephone number submitted by an unusually large number of applicants or customers.
(g) The applicant or customer fails to provide all required personal identifying information on an application or in response to notification that the application is incomplete.
(h) Personal identifying information is not consistent with personal identifying information that is on file with the financial institution or creditor.
(i) The applicant or customer cannot provide authenticating information beyond that which generally would be available from a wallet or consumer report.
(4) Unusual use of or suspicious activity relating to a covered account. Examples include:
(a) Shortly following the notice of a change of address for an account, there is a request for the addition of authorized users on the account.
(b) A new revolving credit account is used in a manner commonly associated with known patterns of fraud patterns, such as where the customer fails to make the first payment or makes an initial payment but no subsequent payments.
(c) An account is used in a manner that is not consistent with established patterns of activity on the account, such as:
1. Nonpayment when there is no history of late or missed payments; and
2. A material change in purchasing or spending patterns.
(d) An account that has been inactive for a long period of time is used (taking into consideration the type of account, the expected pattern of usage and other relevant factors).
(e) Mail sent to the customer is returned repeatedly as undeliverable although transactions continue to be conducted in connection with the customer’s account.
(f) The town is notified that the customer is not receiving paper account statements.
(g) The town is notified of unauthorized charges or transactions in connection with a customer’s account.
(h) The town is notified by a customer, law enforcement or another person that it has opened a fraudulent account for a person engaged in identity theft.
(5) Notices. Notice from customers, law enforcement, victims or other reliable sources regarding possible identity theft or phishing relating to covered accounts.
(Ord. 2009-5, passed 4-27-09)