The following situations pertaining to covered accounts are potential indicators of fraud ("red flags"). Any time a red flag, or a situation closely resembling a red flag, is apparent, it shall be investigated for possible fraudulent activity.
(a) Covered accounts. A covered account includes any account that involves or is designed to permit multiple payments or transactions. Every new and existing customer account that meets the following criteria is covered by this policy:
(1) Business, personal, and household accounts for which there is a reasonably foreseeable risk of identity theft.
(2) Business, personal, and household accounts for which there is a reasonably foreseeable risk to the safety or soundness of the village from identity theft, including financial, operational, compliance, reputation, or litigation risks.
(b) Consumer reporting agency information.
(1) An alert, notification, or warning is received from a consumer reporting agency as defined in § 334.82(b) of the Fair and Accurate Credit Transactions Act of 2003.
(2) A fraud or active duty alert is included with a consumer report.
(3) A notice of credit freeze is received from a consumer reporting agency in response to a request for a consumer report.
(4) A notice of address discrepancy is received from a consumer reporting agency.
(5) A consumer report indicates a pattern of activity inconsistent with the history and usual pattern of activity of a customer, such as:
A. A recent and significant increase in the volume of inquiries.
B. An unusual number of recently established credit relationships.
C. A material change in the use of credit, especially with respect to recently established credit relationships.
D. An account that was closed for cause or identified for abuse of account privileges by a financial institution or creditor.
(c) Suspicious documents.
(1) Documents provided for identification appear to have been altered or forged.
(2) The photograph or physical description on the identification is inconsistent with the appearance of the customer presenting the identification.
(3) Other information on the identification is inconsistent with information provided by the customer presenting the identification.
(4) Other information on the identification is inconsistent with readily accessible information that is on file with the village.
(5) An application to open a covered account appears to have been altered or forged, or gives the appearance of having been destroyed and reassembled.
(d) Suspicious personal identifying information provided by the customer.
(1) Personal identifying information provided by the customer is inconsistent when compared to external information sources used by the village, such as the following:
A. The address does not match any address in the consumer report.
B. The SSN has not been issued or is listed on the Social Security Administration's Death Master File.
(2) Said information is inconsistent with other personal identifying information provided by the customer, such as a lack of correlation between the SSN range and the date of birth.
(3) Said information is associated with known fraudulent activity as indicated by internal or third-party sources used by the village (such as when the address on an application is the same as the address provided on a fraudulent application).
(4) Said information is of a type commonly associated with fraudulent activity as indicated by internal or third-party sources used by the village, such as the following:
A. The address on an application is fictitious, a mail drop, or a prison.
B. The phone number is invalid or is associated with a pager or answering service.
(5) Said information is inconsistent with personal identifying information already on file with the village.
(6) The SSN provided is the same as that submitted by another customer.
(7) The address or telephone number provided is the same as or similar to the address or telephone number submitted by another customer.
(8) The customer fails to provide all required personal identifying information on an application or in response to notification that the application is incomplete.
(9) When asked certain security questions (such as the customer's mother's maiden name or a pet's name), the customer can not provide authenticating information beyond that which generally would be available from a wallet or consumer report.
(e) Suspicious activity related to the covered account.
(1) Shortly following the notice of a change of address for a covered account, the village receives a request for new or additional services.
(2) A new account is used in a manner commonly associated with known fraud patterns (such as when the customer fails to make the first payment or makes an initial payment but no subsequent payments).
(3) A covered account is used in a manner that is inconsistent with established patterns of activity on the account, such as the following:
A. Nonpayment when there is no history of late or missed payments.
B. A material change in purchasing or usage patterns.
(4) A covered account that has been inactive for a reasonably lengthy period of time is used (considering the type of account, the expected pattern of usage, and other relevant factors).
(5) Mail sent to the customer is returned repeatedly as undeliverable although transactions continue to be conducted in connection with the customer's covered account.
(6) The village is notified that the customer is not receiving paper account statements.
(7) The village is notified of unauthorized charges or transactions in connection with a customer's covered account.
(8) The village receives notice from a customer, a victim of identity theft, a law enforcement agency, or any other person regarding possible identity theft in connection with a covered account.
(9) The village is notified by a customer, a victim of identity theft, a law enforcement agency, or any other person that the village has opened a covered account for a person who has purportedly engaged in identity theft.
(Ord. 08-11-02. Passed 1-13-09.)