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FACTA: Red Flag ID Theft Guidelines
(Presented By: Mary Beth Guard and Jack Holzknecht)
Currently, each financial institution can decide for itself what it's going to do to combat ID theft. That's all about to change! Under these new FACT Act rules, specific policies and procedures will be mandated. Your board and senior management will have to be involved. ID theft programs will need to be more formalized and will need to meet specific requirements, based upon a risk assessment you must perform. This Webinar will provide insight into what to expect - and what you need to be doing now to prepare.   | WEBINAR TIME:
11:30AM-1:30PM PT
12:30-2:30PM MT
1:30-3:30PM CT
2:30-4:30PM ET |
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At long last, the proposed rules on Identity Theft Red Flags and Address Discrepancies under the FACT Act have been released. These joint regulations will require each financial institution to establish reasonable policies and procedures for implementing the guidelines, plus credit and debit card issuers will need to have compliant procedures for assessing the validity of address changes, and those who use credit reports will need policies and procedures to use when they receive a notice of address discrepancy from a consumer reporting agency.
WHAT?
The Federal Financial Institution Regulatory Agencies have just released lengthy and detailed proposed regulations and guidelines to implement the red flag identity theft guidelines and address discrepancy provisions in Section 114 the Fair and Accurate Credit Transactions Act (FACT Act). There is a 60-day comment period that commences with publication of the proposal in the Federal Register.
The proposed regulations would require each financial institution to implement a written Identity Theft Prevention Program with reasonable policies and procedures to address the risk of identity theft. The proposal includes guidelines to help institutions identify patterns, practices, and specific forms of activity that indicate a possible risk of ID theft. Relevant indicators of identity theft will need to be incorporated into each institution's written program.
The requirements will be risk-based and will offer some flexibility. Compliance begins with a proper risk assessment that includes controls to address the identity theft risks identified, and the prevention program adopted by an institution must be appropriate to its size and complexity and the nature and scope of its activities.
Responsibility is placed at the highest level of the institution, and a report must be made no less than annually by the staff members who have implementation and compliance duties.
WHY?
With the comment period open, there's an opportunity to help shape the final regulations and guidelines by providing feedback to the regulators about challenges posed by the proposal.
Substantial preparation will be needed to achieve compliance with the new requirements, once adopted. Determining now what the requirements are likely to be will allow you to gain a head start on the required policies and procedures to:
Identify those Red Flags that are relevant to detecting a possible risk of identity theft to customers or to the safety and soundness of the financial institution or creditor;
Verify the identity of persons opening accounts;
Detect the Red Flags that the financial institution or creditor identifies as relevant in connection with the opening of an account or any existing account;
Assess whether the Red Flags detected evidence a risk of identity theft;
Mitigate the risk of identity theft, commensurate with the degree of risk posed;
Train staff to implement the Program; and
Oversee service provider arrangements.
PROGRAM CONTENT
This two-hour program, which reviews all of the major provisions of the proposed regulations and guidelines, will address:
Your risk assessment and developing a risk-based program;
Duties regarding detection, prevention and mitigation of identity theft;
The seven categories of red flags and what you need to know about them;
Primary Objectives of an Identity Theft Program;
Strategies for developing and implementing your Program;
Overseeing service provider arrangements;
Responsibilities of the Board and senior management;
Practical aspects of utilizing the red flags for detecting identity theft;
Special requirements for credit and debit card issuers;
Duties of consumer report users regarding address discrepancies
WHO?
The program is designed for compliance officers, auditors, security officers, and heads of operation.
PRESENTERS
Mary Beth Guard currently serves as Executive Editor of BankersOnline.com and CEO of Glia Group, Inc., Mary Beth has had a long and distinguished career, graduating from law school in 1980. She has focused her work exclusively on the banking industry since 1984. Previously, Mary Beth served as EVP/General Counsel and COO for the Oklahoma Bankers Association, EVP of Specialized Services for Thomson Financial Publishing, and General Counsel for the Oklahoma State Banking Department. Mary Beth is on the advisory board for Bankers' Hotline and Compliance Action, as well as on the editorial board for ABA Bank Compliance magazine. She has presented training programs for virtually every major national financial industry association, as well as more than a dozen state bankers associations and a host of other organizations. In addition, Mary Beth has written more than a thousand banking-related articles and is a BOL Guru.
Jack Holzknecht is a principal with Pegasus Educational Services, LLC, a training firm headquartered in Louisville, Kentucky. He is an experienced consultant who has provided training to thousands of bankers and examiners for twenty-four years. He has the ability to identify the key compliance issues from each regulation. Jack's career began in 1976 as a federal bank examiner. He later headed the form and software and education divisions of a regional consulting company. In that capacity he developed loan and deposit form systems and software. He also developed and presented training programs to bankers in 43 states. Jack has been an instructor at compliance schools presented by the Georgia, Iowa, Kentucky, Pennsylvania, Nebraska, New York and Texas bankers associations. He developed and delivered compliance training for the FDIC and OTS for ten years. He is a Certified Regulatory Compliance Manager and a member of the National Speakers Association. He is also a "BOL Guru" at http://www.bankersonline.com/ and frequently answers compliance questions sent to "Bankers' Threads."
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888-229-8872