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Red Flags and Information Safeguards
A company can't have a Red
Flag rule if it doesn't already have an information security plan.
We have combined information security, mortgage origination, processing
and closing with this Red Flag program to provide a comprehensive
program that can actually be put into use.
The Identity Theft Red Flags
Rule is a part of the Fair and Accurate Credit Transactions Act of 2003
(FACTA). Last year the FTC and five other federal agencies; the Office
of the Comptroller of the Currency, the Board of Governors of the
Federal Reserve System, the Federal Deposit Insurance Corporation, the
Office of Thrift Supervision and the National Credit Union
Administration established “Red Flag” rules that go into effect for
financial institutions and creditors starting November 2008. Much public
input produced an extensive rule is to minimize incidents of Identity
Theft and Fraud related to the handling of customer's non-public
information.
The product includes an
employee training component. Without an employee training
program any plan is useless, and does not meet the requirements of the
law. We have not found another plan that provides this. We
will perform the basic customization, and provide you with a
instructions and recommendations for completing detailed changes, such
as adding vendors. |