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Abstract: 

The rising impact of identity theft on the American economy can be demonstrated when seven agencies combine to issue red flags in regulatory form. Red flags, as with money laundering, are usually issued in agency pronouncements to the industry or individuals served, but here the flags have been added to various regulatory appendices. The combined release, “Identity Theft Red Flags and Address Discrepancies Under the Fair and Accurate Credit Transactions Act of 2003,” would implement sections 114 and 315 of the Act in the release title (the “FACT Act”). The proposal follows the current trend towards risk-basing the program that an institution or creditor must develop. This is not a green light to create the minimum program possible.

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Affiliations:  1: Delta Hedge Publications.