ID Theft Prevention Program
By David Dickinson
In my last blog, I wrote the first installment concerning my attendance at the American Bankers Association's Regulatory Compliance Conference (ABA RCC) in Chicago. Here's another short piece on what I learned in a session on the new ID Theft Prevention Program requirements. These are my notes and not necessarily complete sentences. If you need more information on the FACTA ID Theft requirements be sure to read our June & January 2008 e-newsletters.
- Examination procedures are to be issued by the "end of the Fall". Q&A's coming as well.
- Board Of Directors involvement - seems to be a trend among new requirements.
- You can't elevate everything up to the Board (yet the regulators seem to want to)!
- The Board must approve the INITIAL program and get an annual report. They don't have to approve all program changes throughout the year.
- Banks can incorporate existing policies & programs into the FACT Act program:
- Leverage existing policies. (CIP, Data Protection, Fraud Prevention, Privacy)
- What's this program supposed to look like? We don't really know yet.
- It's not supposed to be something you start from scratch. That's why the examiners said this will only take 25 hours (yeah, right!).