13.40.030 Identification of red flags.
In order to identify relevant red flags, the city shall review and consider the types of covered accounts that it offers and maintains, the methods it provides to open covered accounts, the methods it provides to access its covered accounts, and its previous experiences with identity theft. The city identifies the following red flags, in each of the listed categories:
A. Notification and Warnings from Credit Reporting Agencies – Red Flags.
1. Report of fraud accompanying a credit report;
2. Notice or report from a credit agency of a credit freeze on a customer or applicant;
3. Notice or report from a credit agency of an active duty alert for an applicant; and
4. Indication from a credit report of activity that is inconsistent with a customer’s usual pattern or activity.
B. Suspicious Documents – Red Flags.
1. Identification document or card that appears to be forged, altered or inauthentic;
2. Identification document or card on which a person’s photograph or physical description is not consistent with the person presenting the document;
3. Other document with information that is not consistent with existing customer information (such as a person’s signature on a check appears forged); and
4. Application for service that appears to have been altered or forged.
C. Suspicious Personal Identifying Information – Red Flags.
1. Identifying information presented that is inconsistent with other information the customer provides (such as inconsistent birth dates);
2. Identifying information presented that is inconsistent with other sources of information (for instance, an address not matching an address on a driver’s license);
3. Identifying information presented that is the same as information shown on other applications that were found to be fraudulent;
4. Identifying information presented that is consistent with fraudulent activity (such as an invalid phone number or fictitious billing address);
5. Social Security number presented that is the same as one given by another customer;
6. An address or phone number presented that is the same as that of another person;
7. Failing to provide complete personal identifying information on an application when reminded to do so (however, by law Social Security numbers must not be required); and
8. Identifying information which is not consistent with the information that is on file for the customer.
D. Suspicious Account Activity or Unusual Use of Account – Red Flags.
1. Change of address for an account followed by a request to change the account holder’s name;
2. Payments stop on an otherwise consistently up-to-date account;
3. Account used in a way that is not consistent with prior use (such as very high activity);
4. Mail sent to the account holder is repeatedly returned as undeliverable;
5. Notice to the city that a customer is not receiving mail sent by the city;
6. Notice to the city that an account has unauthorized activity;
7. Breach in the city’s computer system security; and
8. Unauthorized access to or use of customer account information.
E. Alerts from Others – Red Flag.
1. Notice to the city from a customer, a victim of identity theft, a law enforcement authority or other person that it has opened or is maintaining a fraudulent account for a person engaged in identity theft.