At any time that any of the following red flags are present, Employees are to make an appropriate investigation for verification:
(a) Alerts, notifications or warnings from a consumer reporting agency;
(b) A fraud or active duty alert included with a consumer report;
(c) A notice of credit freeze from a consumer reporting agency in response to a request for a consumer report;
(d) A notice of address discrepancy from a consumer reporting agency.
(e) Consumer reports that indicate a pattern of activity inconsistent with the history and usual pattern of activity of an applicant or customer, such as: A recent and significant increase in the volume of inquiries; An unusual number of recently established credit relationships; A material change in the use of credit, especially with respect to recently established credit relationships; or An account that was closed for cause or identified for abuse of account privileges by a financial institution or creditor.
(f) Documents provided for identification that appear to have been altered or forged.
(g) Photograph or physical description on the identification is not consistent with the appearance of the applicant or customer presenting the identification or other information on the identification is not consistent with information provided by the person opening a new covered account or customer presenting the identification.
(h) Information on the identification is not consistent with readily accessible information that is on file with the City (or applicable service provider), such as a signature card or a recent check.
(i) An application appears to have been altered or forged, or gives the appearance of having been destroyed and reassembled.
(j) Personal identifying information provided is inconsistent when compared against external information sources regularly used by the City (or applicable service provider).
(k) Personal identifying information provided is associated with known fraudulent activity as indicated by internal or third-party sources used by the City (or applicable service provider). For example, the address on an application is the same as the address provided on a fraudulent application.
(l) Personal identifying information provided is of a type commonly associated with fraudulent activity as indicated by internal or third-party sources used by the City (or applicable service provider). For example: the address on an application is fictitious, a mail drop, or a prison; or the phone number is invalid or is associated with a pager or answering service.
(m) The social security number provided is the same as that submitted by other persons opening an account or other customers.
(n) The address or telephone number provided is the same as or similar to the address or telephone number submitted by an unusually large number of other customers or other persons opening accounts.
(o) The customer or the person opening the covered account fails to provide all required personal identifying information on an application or in response to notification that the application is incomplete.
(p) Personal identifying information provided is not consistent with personal identifying information that is on file with the City (or applicable service provider).
(q) When using security questions (mother's maiden name, pet's name, etc.), the person opening the covered account or the customer cannot provide authenticating information beyond that which generally would be available from a wallet or consumer report.
(r) Shortly following the notice of a change of address for a covered account, the City (or applicable service provider) receives a request for new, additional, or replacement goods or services, or for the addition of authorized users on the account.
(s) A new 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 no subsequent payments.
(t) A covered account is used in a manner that is not consistent with established patterns of activity on the account. There is, for example nonpayment when there is no history of late or missed payments.
(u) A covered account that has been inactive for a reasonably lengthy period of time is used (taking into consideration the type of account, the expected pattern of usage and other relevant factors).
(v) Mail sent to the customer is returned repeatedly as undeliverable although transactions continue to be conducted in connection with the customer's covered account.
(w) The City (or applicable service provider) is notified that the customer is not receiving paper account statements.
(x) The City (or applicable service provider) is notified of unauthorized charges or transactions in connection with a customer's covered account.
(y) The City (or applicable service provider) receives notice from customers, victims of identity theft, law enforcement authorities, or other persons regarding possible identity theft in connection with covered accounts held by the City (or applicable service provider).
(z) The City (or applicable service provider) is notified by a customer, a victim of identity theft, a law enforcement authority, or any other person that it has opened a fraudulent account for a person engaged in identity theft.
(Ord. 09-58. Passed 9-21-09.)