In order to identify relevant red flags, the Utility considers the types of accounts that it offers and maintains, the methods it provides to open its accounts, the methods it provides to access its accounts, and its previous experiences with identity theft. The Utility identifies the following red flags, in each of the listed categories.
   (A)   Notifications and warnings from consumer credit reporting agencies. Red flags:
      (1)   Report of fraud accompanying a consumer credit report;
      (2)   Notice or report from a consumer credit agency of a credit freeze on a customer or applicant;
      (3)   Notice or report from a consumer credit agency of an active duty alert for an applicant; and
      (4)   Indication from a consumer credit report of activity that is inconsistent with a customer’s usual pattern or activity, including but not limited to:
         (a)   Recent and significant increase in volume of inquiries;
         (b)   Unusual number of recent credit applications;
         (c)   A material change in use of credit; and
         (d)   Accounts closed for cause or abuse.
   (B)   Suspicious documents.  Red flags:
      (1)   Identification document or card that appears to be forged, altered or inauthentic;
      (2)   Identification document or card on which a person’s photograph or physical description is not consistent with the person presenting the document;
      (3)   Other document with information that is not consistent with existing customer information (such as if a person’s signature on a check appears forged); and
      (4)   Application for service that appears to have been altered or forged.
   (C)   Suspicious personal identifying information.  Red flags:
      (1)   Identifying information presented that is inconsistent with other information the customer provides (example: inconsistent birth dates, lack of correlation between Social Security number range and date of birth);
      (2)   Identifying information presented that is inconsistent with other sources of information (for instance, Social Security number or an address not matching an address on a credit report);
      (3)   Identifying information presented that is the same as information shown on other applications that were found to be fraudulent;
      (4)   Identifying information presented that is consistent with fraudulent activity (such as an invalid phone number or fictitious billing address);
      (5)   Social Security number presented that is the same as one given by another customer;
      (6)   An address or phone number presented that is the same as that of another person;
      (7)   A person fails to provide complete personal identifying information on an application when reminded to do so (however, by law social security numbers must not be required) or an applicant cannot provide information requested beyond what could commonly be found in a purse or wallet; and
      (8)   A person’s identifying information is not consistent with the information that is on file for the customer.
   (D)   Suspicious account activity or unusual use of account.  Red flags:
      (1)   Change of address for an account followed by a request to change the account holder’s name;
      (2)   Payments stop on an otherwise consistently up-to-date account;
      (3)   Account used in a way that is not consistent with prior use (example: very high activity);
      (4)   Mail sent to the account holder is repeatedly returned as undeliverable;
      (5)   Notice to the Utility that a customer is not receiving mail sent by the Utility;
      (6)   Notice to the Utility that an account has unauthorized activity;
      (7)   Breach in the Utility’s computer system security; and
      (8)   Unauthorized access to or use of customer account information.
   (E)   Alerts from others. Red flag: notice to the Utility from a customer, identity theft victim, fraud detection service, law enforcement or other person that it has opened or is maintaining a fraudulent account for a person engaged in identity theft.
(Ord. 08-09, passed 7-13-2009)