The City of Cle Elum developed this Identity Theft Prevention Program (“program”) pursuant to the Federal Trade Commission’s Red Flags Rule (“Rule”), which implements Sections 114 and 315 of the Fair and Accurate Credit Transactions Act of 2003. This program was developed with the oversight and approval of the city’s finance director. After consideration of the size and complexity of the city’s operations and account systems, and the nature and scope of the city’s activities, the city council determined that this program was appropriate for the city, and therefore approved this program by the adoption of Ordinance No. 1313 on March 24, 2009.