(A) After careful examination of our accounts, including the methods by which we open access and past experience with identity theft, the following events/occurrences reasonably indicate the potential for identity theft and should be considered “red flags” for purposes of this policy.
(B) Alerts, notifications, or other warnings received from consumer reporting agencies or service providers, such as fraud detections services.
(C) The presentation of suspicious documents, such as:
(1) Document provided for identification that appears to have been altered or forged;
(2) The photograph or physical description on the identification is not consistent with the appearance of the applicant or customer presenting the identification;
(3) Other information on the identification is not consistent with information provided by the person opening a new covered account or customer presenting the identification;
(4) Other information on the identification is not consistent with readily accessible information that is on file with the financial institution or creditor, such as a signature card or a recent check; or
(5) An application appears to have been altered or forged, or gives the appearance of having been destroyed and reassembled.
(D) The presentation of suspicious personal identifying information, such as a suspicious address changes:
(1) Personal identifying information provided is inconsistent when compared against external information sources used by the town;
(2) Personal identifying information provided by the customer is not consistent with other personal identifying information provided by the customer. For example, there is a lack of correlation between the Social Security number range and date of birth; or
(3) Personal identifying information provided is associated with known fraudulent activity as indicated by internal or third-party sources used by the town, for example, the address on an application is the same as the address provided on a fraudulent application.
(E) The phone number on an application is the same as the number provided on a fraudulent application:
(1) Personal identifying information provided is of a type commonly associated with fraudulent activity as indicated by internal or third-party sources used by the financial institution or creditor;
(2) For example:
(a) The address on an application is fictitious, a mail drop, or a prison; or the phone number is invalid, or is associated with a pager or answering service;
(b) The Social Security number provided is the same as that submitted by other persons opening an account or other customers;
(c) The address or telephone number provided is the same as or similar to the account number or telephone number submitted by an unusually large number of other persons opening accounts or other customers;
(d) The person opening the covered account or the customer fails to provide all required personal identifying information on an application or in response to notification that the application is incomplete; or
(e) Personal identifying information provided is not consistent with personal identifying information that is on file with the town.
(3) If the town uses challenge questions, the person opening the covered account or the customer cannot provide authenticating information beyond that which generally would be available from a wallet or consumer report:
(a) The unusual use of, or other suspicious activity related to, a covered account;
(b) Notice from customers, victims of identity theft, law enforcement authorities, or other persons regarding possible identity theft in connection with covered accounts held by the town; or
(c) The town is notified by a customer, a victim of identity theft, a law enforcement authority, or any other person that it has opened a fraudulent account for a person engaged in identity theft.
(2013 Code, § 18-67.2)