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Program Details <br />Relevant Red Flays <br />Red flags are warning signs or activities that alert a creditor to potential identity theft. The <br />guidelines published by the FTC include 26 examples of red flags which fall into the five <br />categories below: <br />• Alerts, notifications or other warnings received from consumer reporting agencies or <br />service providers <br />• Presentation of suspicious documents <br />• Presentation of suspicious personal identifying information <br />• Unusual use of, or other suspicious activity related to, a covered account <br />• Notice from customers, victims of identity theft, or law enforcement authorities <br />After reviewing the FTC guidelines and examples, the Finance Department determined that the <br />following red flags are applicable to certain accounts. These red flags and the appropriate <br />responses are the focus of this program. <br />1. Suspicious Documents and Activities: <br />a. Documents provided for identification appear to have been altered or forged. <br />b. The photograph on the identification is not consistent with the physical <br />appearance of the customer. <br />c. Other information on the identification is not consistent with information <br />provided by the customer. <br />d. The customer does not provide required identification documents when <br />attempting to establish an account or make a payment. <br />e. A customer refuses to provide proof of identity when discussing an established <br />account. <br />f. A person other than the account holder or co-applicant requests information or <br />asks to make changes to an established account. <br />g. An employee requests access to the billing system or information about an <br />account, and the request is inconsistent with the employee's role in the City. <br />2. A customer notifies the Finance Department of any of the following activities: <br />a. Account statements are not being received several months in a row. <br />b. Unauthorized changes to an account. <br />c. Unauthorized charges on an account. <br />d. Fraudulent activity on the customer's bank account or credit card that is used to <br />pay charges. <br />3. The Finance Department is notified by a customer, a victim of identity theft, or a member <br />of law enforcement that an account has been opened for a person engaged in identity <br />theft. <br />Identity Theft Prevention Program 2 of 4 <br />