identify and respond to Red Flags which may indicate potential identity theft. Consumer Alerts and Identity Theft Protections . Respond appropriately to any red flags that are detected to prevent and mitigate identity theft; and 4. Cell: A11 Comment: Appendix J, Section I states a credit union may incorporate existing policies and procedures that control reasonably foreseeable risks to members or the safety and soundness of the credit union from identity theft. Appendix B : Statutory and Regulatory Matrix . The FCRA is a part of a group of acts contained in the Federal Consumer Credit Protection Act such as the Truth in Lending Act and the Fair Debt Collection Practices Act. Consider whether your procedures should differ if an identity verification or authentication is taking place in person, by telephone, mail, or online. Summary. procedures” to: 1. Identification of Red Flags In the course of caring for patients, SJH employees and physicians may encounter inconsistent or suspicious documents, information or activity that may signal identity theft. Detect red flags that have been incorporated into the Program; 3. Bank Secrecy Act, Customer Identification Program and Customer Information Security Program) to determine whether there are deficiencies that adversely affect the financial institution’s ability to comply with the Identity Theft Red Flags Rules (red flag rules). The Office of the Comptroller of the Currency (OCC) is issuing new Fair Credit Reporting Act (FCRA) examination procedures for rules addressing affiliate marketing, identity-theft red flags, and address discrepancies. 2. Review examination findings in other areas (e.g. 1: Appendix A . It is the policy of [physician practice name] to follow all federal and state laws and reporting requirements regarding identity theft. Policies and procedures . 38: Module 6 . Policy . These new examination procedures are additions to the existing FCRA procedures contained in OCC Bulletin 2006-49. Examination Procedures : 44. Specifically, … The new examination procedures … William Henley, Director, IT Risk Management at the OTS, says that the exam procedures show what institutions can expect post-Nov. 1 during an ID Theft Red Flag examination. Identify red flags for the covered accounts the financial institution offers or maintains and incorporate those red flags into the Program; 2. Summary This letter establishes the Federal Reserve's expectations for Federal Reserve-supervised financial institutions and examination staff with respect to the final rules and guidelines regarding identity theft red flags and other … 3. 2. Detect Red Flags. The Fair Credit Reporting Act (FCRA) became effective on April 25, 1971. SJH identifies the following as potential red flags: 1. 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