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CITY OF SAN LEANDRO <br />STAFF REPORT <br />DATE: <br />TO: <br />FROM: <br />BY: <br />November 16, 2009 <br />APPROVED AND <br />FORWARDED <br />TO CITY COUNCIL <br />Stephen Hollister, <br />City Manager <br />Stephen Hollister, City Manager <br />Perry Carter, Interim Finance Director~.~- <br />Mary Ann Perini, Budget & Compliance Manager /~~ <br />SUBJECT PROJECT/PROJECT DESCRIPTION: <br />A RESOLUTION APPROVING THE IDENTITY THEFT PREVENTION PROGRAM IN <br />ACCORDANCE WITH FEDERAL TRADE COMMISSION REGULATIONS. <br />SUMMARY AND RECOMMENDATION <br />Staff recommends City Council approval of the Identity Theft Prevention Program resolution in <br />accordance with Federal Trade Commission Regulations. <br />BACKGROUND <br />The Federal Trade Commission Red Flags Rule which implements Section 114 of the Fair and <br />Accurate Credit Transactions (FACT) Act of 2003 (16 C.F.R. § 681.2) requires creditors with <br />covered accounts to develop and implement a written Identity Theft Prevention Program to <br />detect, prevent and mitigate identity theft in connection with opening or modifying customer <br />accounts. <br />The Red Flags Rule (Rule) defines Identity Theft as "fraud committed using the identifying <br />information of another person" and a Red Flag as a pattern, practice, or specific activity that <br />indicates the possible existence of identity theft. According to the Rule, municipal and lending <br />programs are subject to the Rule requirements. The Rule defines creditors to include non-profit <br />and government entities that defer payment for goods or services. The City of San Leandro and <br />the City's Water Pollution Control Division offer such services to the public. <br />Key Program Provisions <br />The proposed program in Attachment A largely sets forth in writing the identity protection <br />practices the City has followed for many years. Key features of the proposed program include: <br />