RED FLAG/OFAC COMPLIANCE SYSTEM

Financial institutions and creditors are now required to develop and implement written identity theft prevention programs under the new "Red Flags Rules."  The Red Flags Rules are part of the Fair and Accurate Credit Transactions (FACT) Act of 2003. Under these Rules, financial institutions and creditors with covered accounts must have identity theft prevention programs in place by May 1, 2009, to identify, detect, and respond to patterns, practices, or specific activities that could indicate identity theft.  The Red Flag Compliance Tool has an easy to follow format that will make the Compliance resolution process easy to complete. The Tool has been developed to be intuitive and to minimize the training required to make users productive. 

System Features

There are two version of the Red Flag Rules Compliance Tool available.

EXPRESS VERSION

.  Ability to enter necessary customer information through an input screen or by scanning the Customer’s driver’s license into a scanning device.

.   A task list describing each task that needs to be completed before the Red Flag Rules can be satisfied and Compliance can be achieved

.   A comprehensive Customer Compliance Summary Report that includes the customer address information, a Red Flag Compliance Summary, an OFAC summary, and, if necessary,  a Red Flag Rules Compliance Discrepancy summary.   The front of the Drivers License can be printed thus avoiding using a copy machine to make a copy. 

.   A Red Flag Scoreboard that gives a running total of how many Red Flag rules are in each various stage of compliance.

.   A Notes function to identity information that may need to be reviewed later or can be  printed with the Customer Compliance Summary Report if needed to explain discrepancies

.   A “Not Unresolved” button that when clicked will display the various Red Flag Rules that are Non Compliant or Not Resolved.  For each rule, a How to Resolve button can be clicked that will give detailed instructions on how to satisfactorily resolve that

    particular rule.

.   Provide a simple set of Yes/No questions that can help verify the customer’s identity and resolve many of the Red Flag Rules.  

.  The ability to do a more comprehensive OFAC verification than the traditional character by character method does. .

.  An easy to use Help feature that minimizes training and speeds task completion

.  Verifies that Customer’s Social Security Number has actually been issued and the state the SSN was issued in.

.  Driver’s License number provided by customer is an incorrect format for that state. 

.  Checks the City, State Zip Code combination to verify it is valid   

 

COMPREHENSIVE VERSION

In addition to the functionality available with the Express Version, the Comprehensive version also has these additional features:

.   An Identity Verification process that allows the Dealership to ask several ‘out of wallet’ questions to verify the Customer’s identity. The number of correct and incorrect answers as well the percentage of correct answers will be provided.  

.  A comparison of the Customer’s Drivers License Address information with the address information maintained by the large Credit Agencies. Any discrepancies are noted and need to be resolved to satisfy specific Red Flag Rules.

. Minimize potential violations by verifying that:

.  Customer’s Social Security Number does not appear on the SSN Death Master list.

.  The issue date range of the Customer’s Social Security Number and a comparison with the Customer’s birth year.

.  Customer’s address and/or phone numbers are not associated with high risk activity, is not vacant or is not missing some required information  (ex. Apartment number is missing for an address identified  as an apartment)

.   Verifies that, for phone numbers that were provided, that the area code is correct for that state

   

Provides additional information that may point out possible identity discrepancies such as:

.   Identifies Customer Address as being registered for Residential, Business or Mixed-Use. 

.   A name other than that given by the Customer’s is associated with the given address

.   The street number associated with the street address is invalid

.    That a phone number provided was not a pager.

.   Driver’s License number has indeed been issued 

ORGANIZATIONAL COMPLIANCE

In addition to the Red Flag Compliance Tool there are other product features to help organization achieve complete compliance. 

 I. Identity Theft Prevention Program (ITPP)  Creation and Maintenance Module.  The purpose of this module is to provide a simple step-by-step process to create an ITPP. The primary purpose of the ITPP is to identity covered accounts and the level of risk for each type. It also requires you to document your service provider arrangements and the training of your employees. By being prompted to entering several pieces of information and answering a few questions, the Module will generate an Identity Theft Prevention Program in a matter of minutes. The ITPP can be printed at any time or modified as necessary to maintain compliance.

II. The Employee Training Module.   This module contains two sections, the Training Guide which exists in two formats, the PowerPoint version and the full text version which includes direct references from the FTC official documents. The second section of the Training Module is the Testing program which offers a test to complete the training process. Anyone that has completed the training process, including the test, will be entered into the Identity Theft Prevention Program to fulfill the requirement of tracking employees that have completed the training.  The Red Flag Compliance Tool also has a very extensive documentation package that will allow users to become proficient with the tool in just minutes.

III. The Discrepancy Notification Application  This feature of the application gives Owners and General Managers the ability to monitor their Dealership(s) by providing them a daily Email Alert for the previous day's activity.  The alert will be triggered for any Customer(s) with either “Red Flag Rule” Violations or a Compliance Process that is incorrect or incomplete.  There is also functionality that gives the Owners or General Managers the ability to view specific issues for the Customer that triggered the alert.  Deficiencies in training are also detected and reported.    

IV. Reporting Module. The purpose of the Reporting module is to give management access to a variety of reports and queries that can be used to track the effective of their Compliance program. These queries can be modified to produce reports over specific time frames.