The Fair Credit Reporting Act (FCRA) became effective on April 25, 1971. 3. Identification of Red Flags In the course of caring for patients, SJH employees and physicians may encounter inconsistent or suspicious documents, information or activity that may signal identity theft. The FCRA is a part of a group of acts contained in the Federal Consumer Credit Protection Act such as the Truth in Lending Act and the Fair Debt Collection Practices Act. Policies and procedures . Policy . The Office of the Comptroller of the Currency (OCC) is issuing new Fair Credit Reporting Act (FCRA) examination procedures for rules addressing affiliate marketing, identity-theft red flags, and address discrepancies. Appendix B : Statutory and Regulatory Matrix . procedures” to: 1. William Henley, Director, IT Risk Management at the OTS, says that the exam procedures show what institutions can expect post-Nov. 1 during an ID Theft Red Flag examination. identify and respond to Red Flags which may indicate potential identity theft. Sometimes, using identity verification and authentication methods can help you detect red flags. Identify red flags for the covered accounts the financial institution offers or maintains and incorporate those red flags into the Program; 2. Summary. Consumer Alerts and Identity Theft Protections . Respond appropriately to any red flags that are detected to prevent and mitigate identity theft; and 4. 2. New accounts. Detect Red Flags. The new examination procedures … Requirements for Consumer Reporting Agencies : TBD. 2. Review examination findings in other areas (e.g. It is the policy of [physician practice name] to follow all federal and state laws and reporting requirements regarding identity theft. The Red Flags Rule does not require a credit union to develop an all encompassing standalone written 38: Module 6 . 1: Appendix A . FIL-105-2008: Identity Theft Red Flags, Address Discrepancies, and Change of Address Regulations Examination Procedures: Guidance: October 16, 2008: FIL-100-2007: Identity Theft Red Flags—Interagency Final Regulation and Guidelines: Guidance: November 15, 2007: FIL-32-2007: FDIC's Supervisory Policy on Identity Theft: Guidance: April 11, 2007 Identity theft prevention and detection and Red Flags Rule compliance . Specifically, … Consider whether your procedures should differ if an identity verification or authentication is taking place in person, by telephone, mail, or online. Bank Secrecy Act, Customer Identification Program and Customer Information Security Program) to determine whether there are deficiencies that adversely affect the financial institution’s ability to comply with the Identity Theft Red Flags Rules (red flag rules). Examination Procedures : 44. These new examination procedures are additions to the existing FCRA procedures contained in OCC Bulletin 2006-49. 60: 1 This Module will be written and incorporated into the examination procedures… SJH identifies the following as potential red flags: 1. Summary This letter establishes the Federal Reserve's expectations for Federal Reserve-supervised financial institutions and examination staff with respect to the final rules and guidelines regarding identity theft red flags and other … Detect red flags that have been incorporated into the Program; 3. Cell: A11 Comment: Appendix J, Section I states a credit union may incorporate existing policies and procedures that control reasonably foreseeable risks to members or the safety and soundness of the credit union from identity theft. You detect red flags into the Program ; 2 potential red flags which may indicate potential theft... Other areas ( e.g the policy of [ physician practice name ] to follow all and. 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