It’s Been a Month Already? Time to Start Looking Ahead.

by Keir Breitenfeld 2 min read December 2, 2008

The Federal Trade Commission (FTC) suspended enforcement of the new Red Flag Rule until May 1, 2009. According to the FTC’s Enforcement Policy, “…during the course of the Commission’s education and outreach efforts following publication of the rule, the Commission has learned that some industries and entities within the FTC’s jurisdiction have expressed confusion and uncertainty about their coverage under the rule. These entities indicated that they were not aware that they were undertaking activities that would cause them to fall within FACTA Sections 114 and 315definitions of ‘creditor’ or ’financial institution’.”

So, depending upon which enforcement entity (or entities) will be knocking on your door in the coming months, you may (and I emphasize “may”) have some extra time to get your house in order. While many of you are likely confident that you have a compliant written and operational Identity Theft Prevention Program, this break in the action can be a great time to take care of setting up some ongoing procedures for keeping your program up to date. Here are some ideas to keep in mind along the way:

1.Make sure you have clear responsibilities and accountabilities identified and assigned to appropriate persons. Lack thereof may lead to everyone thinking someone else is keeping tabs.

2.Start setting the stage for a process to update your program based on:

a.Your new experiences with identity theft;
b.Changes in methods of identity theft;
c.Changes in methods to detect, prevent, and mitigate identity theft;
d.Changes in the types of accounts you offer or maintain; and
e.Changes in your business arrangements, including mergers, acquisitions, alliances, joint ventures and service provider arrangements.

3.Set up a process for program review at the board level. Remember that your program does not have to be approved by your board of directors annually, but the board (or a committee of the board) or senior management must review reports regarding your program each year. They must approve any material changes to your program should they occur.

4.Prepare now for follow up actions associated with your first Red Flag Rule examination(s). There will surely be suggestions or mandates stemming from that exercise, and now is a good time to start securing appropriate resources and time.

My key message here is that, while there may be lull in the world of Red Flags activity, this is a great time to keep momentum in your program development and upkeep by planning for the next wave of updates and your impending examinations. Best of luck.

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The Email Address as Your Most Powerful Identity Signal

The why behind Experian's acquisition of AtData What happens when a comprehensive email intelligence database joins a global leader in data, analytics and fraud prevention? The acquisition of AtData adds 25+ years of building a complete view of email as an identity signal. Financial institutions can recognize, engage and protect customers unlocking a new standard for the way their teams work and the customer experience. That's what Experian's acquisition of AtData delivers. How we got here Not all email addresses tell the same story. Some are newly created. Some exhibit bot-like patterns. Some are inconsistent with every other signal you have about that person. Imagine a real customer. You have a job. You shop online. You have a primary email from your employer, a personal Gmail you've used for 15 years, and an old Yahoo address you still use for shopping because you've been using it since college. You're an engaged customer who interacts with brands, makes purchases and pays bills on time. But each system sees a different version of you. When you apply for credit, the lender sees one email. When you shop, the retailer sees another. When you sign up for a service, you might use the third. For financial institutions: You slow down the approval process to manually verify identity or approve applicants without the full picture. For retailers: You can't tell which version of "customer" is the most engaged, so you either over-mail or under-serve. For fraud systems: Sees a new account created under one email and flags it as suspicious because it doesn't have the history. This was the original problem AtData was built to solve in 1999. Twenty-five years later, that problem didn’t go away, it became more complex. Email fragmentation and device sharing are more common, and identity theft is more sophisticated. Capabilities that now work together Experian has built sophisticated identity and fraud solutions backed by consumer data resources and decades of expertise in credit and risk. AtData brought the ability to assess whether an email address is trustworthy, reachable and consistent—at scale, in real time. Experian is now making email intelligence foundational, not optional. This matters for: Fraud prevention and risk management: Distinguishing a returning customer from a new threat. Knowing whether an email is newly created, exhibiting bot-like patterns or inconsistent with other identities is crucial. Compliance: Building audit trails that can explain identity decisions. Email data history and behavioral signals create the documentation needed to defend your decisions. Credit: Verifying identity in a world where traditional signals are shifting. Email signals provide a persistent, durable identifier that confirms who someone actually is. Marketing: Reaching the right person across email, mail and digital channels. Email intelligence reveals which addresses are actively engaged and reachable. Research shows email remains one of the highest-ROI marketing channels outperforming paid search and social advertising1. The problem every marketer faces: You end up burning budget on addresses that bounce, are unmonitored or are associated with users who never open mail. For credit marketing specifically, email enables faster, more targeted delivery of firm offers across channels, something that's increasingly important in a post-cookie world. "Email is a persistent identifier in a fragmented world. It's what connects a person's postal address, phones, devices, behaviors—the full picture of who they are. By embedding that into our infrastructure, we're not just adding another data point. We're fundamentally improving how businesses understand who their customers are."- Ashley Knight, Senior Vice President, Financial Services and Data Why now? AI is reshaping how decisions are made in every industry. Models are getting faster, more automated and more embedded in core workflows. But AI is only as effective as the data behind it. Fragmented data + fast models = faster, larger-scale misclassifications. In an era of synthetic identities, AI agents, deepfakes and AI-generated activity, the value of durable, persistent, real-world data signals has increased dramatically. Deloitte’s Center for Financial Services projects that generative AI could drive fraud losses in the U.S. up to $40 billion by 2027, a 32% growth rate since 2023. And email sits at the center of it with business email compromise already being one of the most common and costly fraud types. People change phones, move homes and swap devices, but they often hold onto their email for years. That's the signal that protects your business, and the one we've built into the core of how we help you make decisions with confidence. View the press release here

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