Working with clients in the financial sector means keeping an eye toward compliance and regulations like the Gramm-Leach-Bliley Act (GLB), the Fair Credit Reporting Act (FCRA) or Fair and Accurate Credit Transactions Act (FACTA). It doesn’t really matter what kind of product it is, if a client is a financial institution (FI) of some kind, one of these three pieces of legislation is probably going to apply. The good part is, these clients know it and typically have staff dedicated to these functions. In my experience, where most clients need help is in understanding which regulations apply or what might be allowed under each. The truth is, a product designed to minimize fraud, like knowledge based authentication, will function the same whether using FCRA regulated or non-FCRA regulated data. The differences will be in the fraud models used with the product, the decisioning strategies set-up, the questions asked and the data sources of those questions. Under GLB it is acceptable to use fraud analytics for detection purposes, as fraud detection is an approved GLB exception. However, under FCRA rules, fraud detection is not a recognized permissible purpose (for accessing a consumer’s data). Instead, written instructions (of the consumer) may be used as the permissible purpose, or another permissible purpose permitted under FCRA; such as legitimate business need due to risk of financial loss. Fraud best practices dictate engaging with clients, and their compliance teams, to ensure the correct product has been selected based on client fraud trends and client needs. A risk based authentication approach, using all available data and appropriately decisioning on that data, whether or not it includes out of wallet questions, provides the most efficient management of risk for clients and best experience for consumers.

Quite a scary new (although in some ways old) form of identity theft in the headlines recently. Here’s a link to the article, which talks about how children’s dormant Social Security numbers are being found and sold by companies online under the guise of CPN’s – aka credit profile numbers or credit protection numbers.  Using deceased, “found”, or otherwise illicitly obtained Social Security numbers is not something new.  Experian’s and any good identity verification tool is going to check against the Social Security Administration’s list of numbers listed as deceased as well as check to ensure the submitted number is in an SSA valid issue range.  But the two things I find most troubling here are: One, the sellers have found a way around the law by not calling them Social Security numbers and calling them CPN’s instead.  That seems ludicrous!  But, in fact, the article goes on to state that “Because the numbers exist in a legal gray area, federal investigators have not figured out a way to prosecute the people involved”. Two, because of the anonymity and the ability to quickly set up and abandon “shop”, the online marketplace is the perfect venue for both buyer and seller to connect with minimal risk of being caught. What can we as consumers and businesses take away from this?  As consumers, we’re reminded to be ever vigilant about the disclosure of not only OUR Social Security number but that of our family members as well.  For businesses, it’s a reminder to take advantage of additional identity verification and fraud prediction tools, such as Experian’s Precise ID, Knowledge IQ, and BizID, when making credit decisions or opening accounts rather than relying solely on consumer credit scores.

Quite a scary new (although in some ways old) form of identity theft in the headlines recently. Here’s a link to the article, which talks about how children’s dormant Social Security numbers are being found and sold by companies online under the guise of CPN’s – aka credit profile numbers or credit protection numbers. Using deceased, “found”, or otherwise illicitly obtained Social Security numbers is not something new. Most identity theft prevention programs consider deceased and non-issued ranges as identity theft red flags under the FACTA Red Flag guidelines. In fact, Experian’s and any good identity verification tool is going to check against the Social Security Administration’s list of numbers listed as deceased as well as ensure the submitted number is in an SSA valid issue range – providing fraud alerts if not. A child’s valid but dormant Social Security number, however, would not flag as either. The two things I find most troubling here are: One, the sellers have found a way around the law by not calling them Social Security numbers and calling them CPN’s instead. That seems ludicrous! But, in fact, the article goes on to state that “Because the numbers exist in a legal gray area, federal investigators have not figured out a way to prosecute the people involved”. Two, because of the anonymity and the ability to quickly set up and abandon “shop”, the online marketplace is the perfect venue for both buyer and seller to connect with minimal risk of being caught. What can we as consumers and businesses take away from this? As consumers, we’re reminded to be ever vigilant about the disclosure of not only OUR Social Security number but that of our family members as well. For businesses, it’s a reminder to take advantage of additional identity verification and fraud prediction tools, such as Experian’s Precise ID, Knowledge IQ, and BizID, when making credit decisions or opening accounts rather than relying solely on consumer credit scores. Knowledge IQ’s knowledge based authentication offers out of wallet questions that may help ensure you’re dealing with the true consumer.