(a) The employees of the City that interact directly with customers on a day-to-day basis shall have the initial responsibility for monitoring the information and documentation provided by the customer and any third-party service provider in connection with the opening of new accounts and the modification of or access to existing accounts and the detection of any red flags that might arise.
(b) Management shall see to it that all employees who might be called upon to assist a customer with the opening of a new account or with modifying or otherwise accessing an existing account are properly trained such that they have a working familiarity with the relevant red flags identified in this program so as to be able to recognize any red flags that might surface in connection with the transaction.
(c) An employee who is not sufficiently trained to recognize the red flags identified in this program shall not open a new account for any customer, modify any existing account or otherwise provide any customer with access to information in an existing account without the direct supervision and specific approval of a management employee.
(d) Management employees shall be properly trained such that they can recognize the relevant red flags identified in this program and exercise sound judgment in connection with the response to any unresolved red flags that may present themselves in connection with the opening of a new account or with modifying or accessing of an existing account. Management employees shall be responsible for making the final decision on any such unresolved red flags.
(e) The Program Administrator shall establish from time to time a written policy setting forth the manner in which a prospective new customer may apply for service, the information and documentation to be provided by the prospective customer in connection with an application for a new utility service account, the steps to be taken by the employee assisting the customer with the application in verifying the customer's identity and the manner in which the information and documentation provided by the customer and any third-party service provider shall be maintained.
(f) Such policy shall be generally consistent with the spirit of the Customer Identification Program rules of the USA Patriot Act but need not be as detailed. The Program Administrator shall establish from time to time a written policy setting forth the manner in which customers with accounts shall establish their identity before being allowed to make modifications to or otherwise gain access to existing accounts.
(Res. 05-2009. Passed 4-2-09.)