(A) All detections of suspicious red flags, or the taking of any of the response mechanisms set forth in division (B) below, by any employee of the city must be reported to the senior management official, that is, the City Clerk-Treasurer, as soon as practicable.
(B) Any employee of the city who may suspect fraud or identity theft or detect a red flag shall implement one or more of the following response mechanisms, as applicable to the given situation:
(1) Ask the applicant for additional documentation or information;
(2) Refuse to open an account;
(3) Close an account;
(4) Refuse to close an account;
(5) Only after consultation with the City Clerk-Treasurer and the city’s legal counsel, refuse to provide account information or personal information associated with an account;
(6) Label or otherwise identify an account for further monitoring or evaluation;
(7) Immediately cease efforts to collect against an account, either permanently or temporarily;
(8) If a city employee becomes aware of suspected or actual fraudulent use of a customer’s, former customer’s or potential customer’s identity, said employee must notify the City Clerk-Treasurer immediately;
(9) The City Clerk-Treasurer may elect to notify law enforcement, which law enforcement shall consist of either one or both of the City Police Department or the State Police, and if an actual or attempted identity theft occurs, then the City Clerk- Treasurer must notify both of such law enforcement agencies; or
(10) Take any action or nonaction with respect to the applicable situation which is recommended or ordered by the City Clerk-Treasurer after consultation with the City Clerk-Treasurer regarding said situation.
(Ord. 2009-10, passed 6-1-2009)