Identity theft is as big of a concern as ever. I’m sure your financial institution is doing all it can to detect, prevent and mitigate identity theft. The Identity Theft Red Flag rules require you to do this. It’s not a choice! As the end of the year gets closer, make sure you’ve met or plan to meet the ongoing administrative requirements of your program.
First, your program must provide training as needed. Second, you must conduct due diligence and provide proper oversight of third-party service providers. And last, you must provide an annual update to the Board of Directors (or committee thereof) on the status of the financial institution’s identity theft prevention program.
These requirements are easy to forget and/or miss altogether and are an easy citation for examiners and auditors. Now is a good time to take a minute and make sure you’ve met these requirements. Good luck out there!