Red Flag Identity Theft Prevention
Loyola University New Orleans (“university”) has developed an Identity Theft Prevention Program pursuant to the Federal Trade Commission’s Red Flag Rules which implement Section 114 of the Fair and Accurate Credit Transactions Act of 2003.
This policy is pending university Board of Trustees approval and becomes effective May 1, 2009.
Loyola University New Orleans regards any threat of identity theft an immediate and highly important matter and will enforce the following to mitigate any threats.
- Take reasonable steps to control foreseeable risks
- Identify Risk Factors and sources of Red Flags
- Detect any Red Flags through identifying information
- Prevent and mitigate Identity Theft by responding appropriately to risks
- Update policy as new Identity Theft risks emerge
- Administer this policy in an appropriate manner including the training of university staff and monitoring the compliance of all vendors acting on the university’s behalf
- Report only accurate information to credit bureaus and other collection agents
From the appendix to the Red Flag Rules, the following examples have been included in our program.
Alerts, Notifications or Warnings from a Consumer Reporting Agency
- A fraud or active duty alert is included with a consumer report.
- A consumer reporting agency provides a notice of credit freeze in response to a request for a consumer report.
- A consumer reporting agency provides a notice of address discrepancy, as defined in § 41.82(b) of this part.
- A consumer report indicates a pattern of activity that is inconsistent with the history and usual pattern of activity of an applicant or customer.
- Documents provided for identification appear to have been altered or forged.
- The photograph or physical description on the identification is not consistent with the appearance of the applicant or customer presenting the identification.
- Other information on the identification is not consistent with information provided by the person opening a new covered account or customer presenting the identification.
- Other information on the identification is not consistent with readily accessible information that is on file with the university or creditor, such as a signature card or a recent check.
- An application appears to have been altered or forged, or gives the appearance of having been destroyed and reassembled.
Suspicious Personal Identifying Information
- Personal identifying information provided is inconsistent when compared against external information sources used by the university or creditor.
- Personal identifying information provided by the customer is not consistent with other personal identifying information provided by the customer.
- Personal identifying information provided is associated with known fraudulent activity as indicated by internal or third-party sources used by the university or creditor.
- Personal identifying information provided is of a type commonly associated with fraudulent activity as indicated by internal or third-party sources used by the university or creditor.
- The SSN provided is the same as that submitted by other persons opening an account or other customers.
- The address or telephone number provided is the same as or similar to the account number or telephone number submitted by an unusually large number of other persons opening accounts or other customers.
- The person opening the covered account or the customer fails to provide all required personal identifying information on an application or in response to notification that the application is incomplete.
- Personal identifying information provided is not consistent with personal identifying information that is on file with the university or creditor.
- For universities and creditors that use challenge questions, the person opening the covered account or the customer cannot provide authenticating information beyond that which generally would be available from a wallet or consumer report.
Unusual Use of, or Suspicious Activity Related to, the Covered Account
- Shortly following the notice of a change of address for a covered account, the institution or creditor receives a request for a new, additional, or replacement card or a cell phone, or for the addition of authorized users on the account.
- A new revolving credit account is used in a manner commonly associated with known patterns of fraud patterns.
- A covered account is used in a manner that is not consistent with established patterns of activity on the account.
- A covered account that has been inactive for a reasonably lengthy period of time is used (taking into consideration the type of account, the expected pattern of usage and other relevant factors).
- Mail sent to the customer is returned repeatedly as undeliverable although transactions continue to be conducted in connection with the customer’s covered account.
- The university or creditor is notified that the customer is not receiving paper account statements.
- The university or creditor is notified of unauthorized charges or transactions in connection with a customer’s covered account.
Notice From Customers, Victims of Identity Theft, Law Enforcement Authorities, or Other Persons Regarding Possible Identity Theft in Connection With Covered Accounts Held by the University or Creditor
The university or creditor is notified by a customer, a victim of identity theft, a law enforcement authority, or any other person that it has opened a fraudulent account for a person engaged in identity theft.