This template is an optional guide for firms to assist them in fulfilling their requirements under the Federal Trade Commission’s (FTC) Red Flags Rule, which implements obligations imposed by the Fair and Accurate Credit Transactions Act of 2003 (FACT Act).
1) Identify relevant Red Flags that apply to these types of credit (known as “covered accounts”). 2) Develop reasonable policies and procedures to identify, detect, and respond to those relevant Red Flags. 3) Ensure that those policies and procedures are updated periodically to reflect new risks from identity theft.
Our firm’s policy is to protect our customers and their accounts from identity theft and to comply with the FTC’s Red Flags Rule. We will do this by developing and implementing this written ITPP, which is appropriate to our size and complexity, as well as the nature and scope of our activities.
Red flags apply to covered accounts that include newor existing customer information accessed by the creditor or accessed by third parties. Red flags are often discovered by cross‐checking telephone directories, public or internet sources.
FTC Red Flags Rule Sample Red Flags Departments with Covered Accounts may consider using the following examples of Red Flags in connection with Covered Accounts. Alerts, Notifications or Warnings from a Consumer Reporting Agency 1. A fraud or active duty alert is included with a consumer report. 2.
Develop and implement a written identity theft prevention program to address identity theft risks referred to as “red flags.” A “red flag” is a pattern, practice or specific activity that indicates the possible existence of identity theft. 16 C.F.R. § 681.2(b)(9). In other words, suspicious activity that raises a “red flag.”
Specifically, this policy outlines how [physician practice name] will (1) identify, (2) detect and (3) respond to “red flags.” A “red flag” as defined by this policy includes a pattern, practice, or specific account or record activity that indicates possible identity theft.
Jul 21, 2014 · The SEC’s Red Flags Rule applies to SEC-regulated entities that qualify as “financial institutions” or “creditors” under FCRA and requires those financial institutions and creditors that maintain “covered accounts” to adopt identity theft programs.
FTC FACT Act Red Flags Rule Template - International …
FTC FACT Act Red Flags Rule Template. This template is an optional guide for firms to assist them in fulfilling their requirements under the Federal Trade Commission’s Red Flags Rule.
As mentioned above, the idea behind the Red Flags Rule is to require businesses that offer credit to establish policies to detect and thwart identity thieves. The primary goal of the Red Flags Rule in the dealership context is to prevent an identity thief from financing or leasing a vehicle in some-one else’s name.