8348-09 Identity Theft Prevention Program

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5. Red Flags. Six agencies were involved in drafting the red flag rules: The Treasury Deparhnent's Office of Thrift Supervision, The Office of Comptroller of the Currency, The Federal Deposit Insurance Corporation, The Federal Trade Commission, The National Credit Union Administration, and The Federal Reserve System. The City hereby determines that the following aze the relevant Red Flags for purposes of this Program given the relative size of the City of Lakewood and the limited nature and scope of the services that the City provides to its citizens. At any time that any of the following red flags are present, City personnel are to make an appropriate investigation for verification: (a) Alerts, notifications or warnings from a consumer reporting agency; (b) A fraud or active duty alert included with a consumer report; (c) A notice of credit freeze from a consumer reporting agency in response to a request for a consumer report; (d) A notice of address discrepancy from a consumer reporting agency. (e) Consumer reports that indicate a pattern of activity inconsistent with the history and usual pattern of activity of an applicant or customer, such as: A recent and significant increase in the volume of inquiries; An unusual number of recently established credit relationships; A material change in the use of credit, especially with respect to recently established credit relationships; or An account that was closed for cause or identified for abuse of account privileges by a financial institution or creditor. (f) Documents provided for identification that appear to have been altered or forged. (g) Photograph or physical description on the identification is not consistent with the appearance of the applicant or customer presenting the identification or other information on the identification is not consistent with information provided by the person opening a rew covered account or customer presenting the identification. (h) Information on the identification is not consistent with readily accessible information that is on file with the City, such as a signature card or a recent check. (i) An application appears to have been altered or forged, or gives the appearance of having been destroyed and reassembled. (j) Personal identifying information provided is inconsistent when compared against external information sources regulazly used by the City. (k) Personal identifying information provided is associated with known fraudulent activity as indicated by internal or third-party sources used by the City.