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 and such red flags may include:
(A) Alerts from consumer reporting agencies, fraud detection agencies or service providers that may be received in the future by the city. The city does not subscribe to or contract with any consumer reporting agency at this time.
(B) Suspicious documents. Examples of suspicious documents include:
(1) Documents provided for identification that appear to be altered or forged;
(2) Identification on which the photograph or physical description is inconsistent with the appearance of the applicant or customer;
(3) Identification on which the information is inconsistent with information provided by the applicant or customer; or
(4) An application that appears to have been altered or forged, or appears to have been destroyed and reassembled.
(C) Suspicious personal identification, such as suspicious address change. Examples of suspicious identifying information include:
(1) Personal identifying information or a phone number that is inconsistent with external or internal information sources used by the city;
(2) Personal identifying information provided by the customer that is not consistent with other personal identifying information provided by the customer;
(3) Personal identifying information or a phone number or address that is associated with known fraudulent applications or activities as indicated by internal or external sources used by the city;
(4) Other information provided, such as a fictitious mailing address, mail drop addresses, jail addresses, invalid phone numbers, pager numbers or answering services, is associated with fraudulent activity;
(5) The address or telephone number provided is the same or similar to the account number or telephone number submitted by an unusually large number of applicants or customers;
(6) The applicant or customer fails to provide all required personal identifying information on an application or in response to notification that the application is incomplete;
(7) Personal identifying information is not consistent with personal identifying information that is on file with the city.
(D) Unusual use or suspicious activity relating to a covered account. Examples of suspicious activity include:
(1) Shortly following the notice of a change of address for an account, the city receives a request for the addition of authorized users on the account.
(2) A new revolving credit account is used in a manner commonly associated with known patterns of fraud patterns. For example, the customer fails to make the first payment or makes an initial payment but not subsequent payments.
(3) An account is used in a manner that is not consistent with established patterns of activity on the account. There is, for example:
(a) Nonpayment when there is no history of late or missed payments;
(b) A material change in purchasing or spending patterns.
(4) An account that has been inactive for a long period of time is used (taking into consideration 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 account.
(6) The city is notified that the customer is not receiving paper account statements.
(7) The city is notified of unauthorized charges or transactions in connection with a customer’s account.
(8) The city is notified by the customer, law enforcement or another person that it has opened a fraudulent account for a person engaged in identity theft.
(E) Notice from customers, law enforcement, victims or other reliable sources regarding possible identity theft or phising relating to covered accounts.
(Ord. 09-09, passed 4-20-09)