New rules mandated by the FACT Act were finalized in November 2007. The rules require financial institutions to implement Section 114 (Red Flag Guidelines) and Section 315 (Reconciling Address Discrepancies) by November 1, 2008. DD&F's Identity Theft Prevention Program includes the following elements:
- Identity Theft Risk Assessment specific to your institution, which will identify the covered accounts and the associated risk for each type of account.
- Identity Theft Prevention Program with the following components:
- Program Administration
- Risk Management
- Training
- Program Oversight
- Service Provider Oversight
- Program Revisions
- Identifying Red Flags
- Red Flag Detection Procedures
- Red Flag Response Procedures
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