(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 may include:
(1) Suspicious documents. Examples of suspicious documents include:
(a) Documents provided for identification that appear to be forged or altered;
(b) Identification on which the photograph or physical description is inconsistent with the appearance of the applicant or customer; and/or
(c) Identification which is inconsistent with information readily accessible on file with the town.
(2) Suspicious personal identification. Examples of suspicious personal identification include:
(a) Inconsistent personal information; and/or
(b) Lack of personal information beyond that which generally would be available from a wallet or consumer report.
(3) Unusual or suspicious activity relating to a covered account. Examples of unusual or suspicious activity relating to a covered account include:
(a) Customer fails to make first payment or makes an initial payment but no subsequent payments;
(b) Mail sent to the customer is returned although transactions continue to be conducted in connection with the customer’s account;
(c) Suspicious inquiries about covered account information by any person, including persons representing themselves to be the account holder or the account holder’s representative;
(d) The town is notified of unauthorized charges or transactions in connection with a customer’s account; and/or
(e) The town is notified by a customer, law enforcement, or another person that a fraudulent account has been opened for a person engaged in identity theft.
(Ord. G-09-03, passed 4-13-2009)