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The Red Flag Rule requires all financial institutions and creditors to implement an Identity Theft Prevention Program to detect, prevent and mitigate identify theft for covered accounts. The Program must be documented and updated periodically. Updates must reflect changes in risks to customers or to the safety and soundness of the financial institution or creditor from identity theft. The Program must also have the approval of the Board of Directors or a designated Senior Management employee. The Board of Directors shall also have supervision of the implementation of the Program as well as training of the staff and oversight of service providers.
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