In order to identify relevant red flags, the village considers the types of covered accounts that it offers and maintains, the methods it provides to open such covered accounts, the methods it provides to access such covered accounts, and its previous experiences with identity theft. The village identifies the following red flags, in each of the listed categories:
(A) Notifications and warnings from credit report agencies.
(1) Report of fraud accompanying a credit report;
(2) Notice or report from a credit agency of a credit freeze on a customer or applicant;
(3) Notice or report from a credit agency of an active duty alert for an applicant; and
(4) Indication from a credit report of activity that is inconsistent with a customer’s usual pattern or activity.
(B) Suspicious documents.
(1) Identification document or card that appears to be forged, altered or inauthentic;
(2) Identification document or card on which a person’s photograph or physical description is not consistent with the person presenting the document;
(3) Other document with information that is not consistent with existing customer information (such as if a person’s signature on a check appears forged); and
(4) Application for service that appears to have been altered or forged.
(C) Suspicious personal identifying information.
(1) Identifying information presented that is inconsistent with other information the customer provides (example: inconsistent birth dates);
(2) Identifying information presented that is inconsistent with other sources of information (for instance, an address not matching an address on a credit report);
(3) Identifying information presented that is the same as information shown on other applications that were found to be fraudulent;
(4) Identifying information presented that is consistent with fraudulent activity (such as an invalid phone number or fictitious billing address);
(5) Social security number presented that is the same as one given by another customer;
(6) An address or phone number presented that is the same as that of another person;
(7) A person fails to provide complete personal identifying information on an application when reminded to do so (however, by law social security numbers must not be required); and
(8) A person’s identifying information is not consistent with the information that is on file for the customer.
(D) Suspicious account activity or unusual use of covered accounts.
(1) Change of address for a covered account followed by a request to change the covered account holder’s name;
(2) Payments stop on an otherwise consistently up-to-date covered account;
(3) Covered account used in a way that is not consistent with prior use (example: very high activity);
(4) Mail sent to the covered account holder is repeatedly returned as undeliverable;
(5) Notice to the village that a customer is not receiving mail sent by the village;
(6) Notice to the village that a covered account has unauthorized activity;
(7) Breach in the village’s computer system security; and
(8) Unauthorized access to or use of identifying information,
(E) Alerts from others. Notice to the village from a customer, identity theft victim, law enforcement or other person that it has opened or is maintaining a fraudulent covered account for a person engaged in identity theft.
(Res. 2008-1031, passed 11-5-08)