I.C. System: news 11 08 red flag

I.C. System Complies with Red Flag Requirements

St. Paul, Minn. (November 6, 2008) – I.C. System is pleased to announce it is compliant with the Federal Trade Commission’s (FTC) regulations (the Red Flag Rules) that require financial institutions and creditors to develop/implement written identity theft programs. An organization’s programs must identify, detect, and respond to patterns, practices, or specific activities (“red flags”) that could indicate identity theft. Originally, the FTC required the programs to be in place by November 1, 2008, but it has since suspended enforcement until May 1, 2009.

While it is not yet clear if third-party collection agencies are defined as “creditors” for the purposes of compliance/enforcement, I.C. System has taken a proactive approach to compliance. “Identity theft has been a part of our training and we have had procedures in place for those type of claims; the FTC’s regulations prompted us to have our programs reviewed by independent legal counsel to assure we’re doing everything possible to protect consumers and clients,” said Sue Johnson, I.C. System’s Director of Legal Affairs.

I.C. System’s three primary identity theft policies/programs* include:

Identity Theft Program/Red Flag Policy controls foreseeable risks to consumer accounts and controls the safety of accounts and consumers from identity theft. The comprehensive program enables I.C. System personnel to:
-Respond quickly/immediately to “red flags” and prevent and/or mitigate identity theft
-Identify/detect relevant patterns and practices signaling (“red flags”) possible identity theft

Identity Theft Policy ensures the proper and consistent handling of claims. Upon receipt (verbal or written) of an allegation of identity theft, the account immediately follows our documented Dispute Policy procedures.

If a fully completed (valid) Identity Theft Report is received, the account is closed and returned to the client and the consumer’s trade line is deleted.

Notice of Address Discrepancy Policy addresses discrepancies under the Fair and Accurate Credit Transaction Act of 2003. The policy states reconciliation procedures for when a national Credit Reporting Agency provides a substantial discrepancy in response to I.C. System’s request for a consumer’s credit report.

*All policies/programs are reviewed and updated periodically by I.C. System’s Legal Department.