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This program shall be periodically reviewed and updated to reflect changes in risks to customers and the soundness of the township from identity theft. The Supervisor shall consider the township’s experiences with identity theft situation, changes in identity theft methods, changes in identity theft detection and prevention methods, changes in types of accounts the township maintains and changes in the township’s business arrangements with other entities. After considering these factors, the Supervisor shall determine whether changes to the program, including the listing of red flags, are warranted. If warranted, the Supervisor shall present the Township Board with his or her recommended changes and the Board shall make a determination of whether to accept, modify or reject those changes to the program.
(Board and Administrative Policies Manual, § 4.80)