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Identity Theft Prevention Program <br />Pur ose <br />This document was created in order to comply with regulations issued by the Federal Trade <br />Commission (FTC) as part of the implementation of the Fair and Accurate Credit Transaction <br />(FACT) Act of 2003. The FACT Act requires that financial institutions and creditors implement <br />written programs which provide for detection of and response to specific activities ("red flags") <br />that could be related to identity theft. <br />The FTC regulations require that the program must: <br />1. Identify relevant red flags and incorporate them into the program <br />2. Identify ways to detect red flags <br />3. Include appropriate responses to red flags <br />4. Address new and changing risks through periodic program updates <br />5. Include a process for administration and oversight of the program <br />Identity Theft Prevention Program 1 of 4 <br />