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Financial Institution Letters

Identity Theft Red Flags, Address Discrepancies, and Change of Address Regulations
Examination Procedures
FIL-105-2008
October 16, 2008


Summary: The FDIC has issued the attached examination procedures on identity theft "red flags," address discrepancies, and change of address requests.

Highlights:

  • The exam procedures are intended to assist financial institutions in implementing the Identity Theft Red Flags, Address Discrepancies, and Change of Address Regulations, reflecting the requirements of Sections 114 and 315 of the Fair and Accurate Credit Transactions Act of 2003.
  • The regulations require
    • financial institutions and creditors to implement a written identity theft prevention program;
    • card issuers to assess the validity of change of address requests; and
    • users of consumer reports to verify the identity of the subject of a consumer report in the event of a notice of address discrepancy.
  • The regulations and guidelines took effect on January 1, 2008, and compliance is required by November 1, 2008.
  • Risk management examiners will examine institutions for compliance with the red flags regulation (12 CFR 334.90) during risk management examinations. Compliance examiners will examine institutions for compliance with the address discrepancies and change of address regulations (12 CFR 334.82 and 334.91) during compliance examinations.

Distribution:
FDIC-Supervised Banks (Commercial and Savings)

Suggested Routing:
Chief Compliance Officer
Chief Information Security Officer

Related Topics:


  • FIL-100-2007, Identity Theft Red Flags, November 15, 2007


  • FIL-32-2007, Identity Theft, FDIC's Supervisory Policy on Identity Theft, April 11, 2007


  • FIL-27-2005, Guidance on Response Programs for Unauthorized Access to Customer Information and Customer Notice, April 1, 2005


  • FIL-7-2005, Guidelines Requiring the Proper Disposal of Consumer Information, February 2, 2005


  • FIL-22-2001, Guidelines Establishing Standards for Safeguarding Customer Information, March 14, 2001

Attachment:

  • Identity Theft Red Flag, Address Discrepancies, and Change of Address Examination Procedures
  • Identity Theft Red Flag, Address Discrepancies, and Change of Address Examination Procedures - PDF (PDF Help)
  • Contacts:
    Jeffrey Kopchik, Senior Policy Analyst, at
    jkopchik@fdic.gov or (202) 898-3872; or Richard Schwartz,
    Counsel, at rischwartz@fdic.gov or (202) 898-7424

    Printable Format:
    FIL-105-2008 - PDF (PDF Help)

    Note:
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    FDIC financial institution letters (FILs) may be accessed from the FDIC's Web site at www.fdic.gov/news/news/financial/2008/index.html

    Paper copies of FDIC financial institution letters may be obtained through the FDIC's Public Information Center, 3501 Fairfax Drive, E-1002, Arlington, VA 22226 (1-877- 275-3342 or 703-562-2200).




    Last Updated 10/21/2008 communications@fdic.gov