26 Identity Theft Red Flags
The Red Flags Rule regulation specifically
calls out 26 identity theft red flags that companies should consider as part of
their identity theft prevention and training programs. These identity theft red flags are not
only important to consider from a compliance standpoint, but they also establish a baseline for starting risk assessments and risk management. Companies should
consider these 26 identity theft red flags in their risk assessment process and
incorporate the ones that apply to their business in their identity theft prevention program and employee identity theft prevention training.
The Red Flags Rule classifies these
26 red flags by the following 5 categories:
- consumer reports,
- identification documents and information,
- address discrepancy notices,
- suspicious address changes, and
- warning notices
received from customers and other sources.
List of 26 Identity Theft Red Flags
- Consumer report fraud alerts must be considered as a possible
identity theft red flag.
- Notice of
a credit freeze in response to a request for a consumer report is a red flag because a
consumer who placed a credit freeze is less likely to apply for credit.
- Unusual
credit activity, such as an increased number of new accounts, spending or inquiries appear in the credit reports.
- Documents
provided for identification by the customer appear altered or forged.
- Photograph
on ID is inconsistent with the appearance of the customer present.
- Information
on ID card is inconsistent with information provided by the person opening account. For example, the address may not be the same.
- Information
on ID card, such as signature is inconsistent with information on file in the organization.
- Application
appears forged, altered and reassembled.
- Personal information is inconsistent. For example, information on the ID does not
match any address in the consumer report, or, Social Security number has not
been issued, or appears on the Social Security Administration's Death Master
File.
- Lack of correlation between
Social Security number range and date of birth exists.
- Personal identifying
information associated with known fraud activity exists.
- Suspicious information and addresses is supplied, such as a mail drop, prison, or phone numbers associated with
pagers or answering service.
- Social Security number
provided matches identical numbers submitted by another person opening an account or other
customers.
- An address or phone number
matches those supplied by other applicants.
- The person opening the
account is unable to supply identifying information in response to notification
that the application is incomplete.
- Personal information is inconsistent with information already on file at financial institution or
creditor.
- An existing customer is unable to correctly answer challenge questions.
- Shortly after change of
address, creditor receives a request for additional users for the account.
- A consumer reporting agency provides a notice
of address discrepancy.
- Most of available credit is used for cash advances, jewelry or electronics, and customer fails to make
first payment.
- Drastic change in payment
patterns, use of available credit or spending patterns exists.
- An account that has been
inactive for a long time suddenly becomes unusually active.
- Mail sent to customer
repeatedly is returned as undeliverable despite ongoing transactions on the account.
- Financial institution or
creditor is notified that customer is not receiving paper account statements.
- Financial institution or
creditor s notified of unauthorized charges or transactions on customer's
account.
- Financial institution or
creditor is notified that it has opened a fraudulent account for a person engaged
in identity theft.
Learn about the Red Flags Rule compliance offered by Identity Management Institute.