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) Consumer reporting agencies, fraud detection agencies or service providers. For example:
(1) Notice of credit freeze;
(2) Notice of address discrepancy;
(3) Pattern of activity in a consumer report that is inconsistent with the history and usual pattern of activity of an applicant or customer, such as:
(a) Increase in number of inquiries;
(b) Increase in recent credit relationships;
(c) Closed account due to abuse of account privileges.
(B) Suspicious documents.
(1) Documents that appeared altered or forged;
(2) Identification that appears altered or information is inconsistent with information provided by customer;
(3) Applications that appear altered or forged.
(C) Suspicious personal identification, such as suspicious address change.
(1) Personal identification information inconsistent with information reported from a financial institution;
(2) Personal identification has been previously identified and flagged as fraudulent;
(3) Fictitious mailing address, phone numbers, etc.;
(4) Social security number does not match that of the customer or applicant.
(D) Unusual use of or suspicious activity relating to a covered account.
(1) An inactive account is used after a prolonged inactive period;
(2) Noticeable change in pattern of account activity;
(3) Customer notifies the Finance Director or her designee of unauthorized charges or transactions in connection with a customer's account.
(E) Notice from customers, law enforcement, victims or other reliable sources regarding possible identity theft relating to covered accounts.
(Ord. passed 5-4-2009)