In my last entry, I talked about the challenges clients face in trying to meet multiple and complex regulatory requirements, such as FACT Act’s Red Flags Rule and the USA Patriot Act. While these regulations serve both different and shared purposes, there are some common threads between the two:
1. You must consider the type of accounts and methods of account opening: The type of account offered – credit or deposit, consumer or business – as well as the method of opening – phone, online, or face-to-face – has a bearing on the steps you need to take and the process that will be established.
2. Use of consumer name, address, and identification number:The USA Patriot Act requires each of these – plus date of birth – to open a new account. Red Flags stops short of “requiring” these for new account openings, but it consistently illustrates the use of these Personally Identifiable Information (PII) elements as examples of reasonable procedures to detect red flags.
3. Establishing identity through non-documentary verification:Third party information providers, such as a credit reporting agency or data broker, can be used to confirm identity, particularly in the case where the verification is not done in person.
Knowing what’s in common means you can take a look at where to leverage processes or tools to gain operational and cost efficiencies and reduce negative impact on the customer experience. For example, if you’re using any authentication products today to comply with the USA Patriot Act and/or minimize fraud losses, the information you collect from consumers and authentication steps you are already taking now may suffice for a large portion of your Red Flags Identity Theft Prevention Program.
And if you’re considering fraud and compliance products for account opening or account management – it’s clear that you’ll want something flexible that, not only provides identity verification, but scales to the compliance programs you put in place, and those that may be on the horizon.
