Beltway Report

If you are asking yourself "What is a ‘Red Flag’ and "Do I salute if I see one?" take comfort. You are not alone. The federal regulatory agencies, pursuant to the FACT Act, have issued proposed rulemaking regulations regarding "Red Flag" guidelines and the Address Discrepancy Rules. The agencies have requested comment on rules that would require a financial institution or creditor to establish a written, risk-based ID theft program. The program would be required to take into account specified "Red Flags" such as the patterns, practices, and specific forms of activity that could suggest identity theft. In addition, the agencies proposed rules that would require issuers or users of consumer reports to validate address changes and deal with address discrepancies.