1. Citi fraud/identity theft TRAINING
December, 2014
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2. Confidential and Proprietary
FACTA (Fair and Accurate Credit Transaction Act) – Congress passed in 2003 as an amendment to the FCRA to protect consumers against identity theft and other forms of consumer fraud. This places limits on how creditors can obtain, use, re-disclose, and share consumer credit and medical information. FACTA “disposal rules” were added regarding the disposal of confidential customer, employee, and vendor records.
Allowance of a free credit report once every 12 months from each of the 3 credit bureau reporting agencies
Provides ability for Consumers to place “alerts” on their specific trades if identity theft is suspected
Systems that print payment card receipts must employ “PAN Truncation” (personal account number truncation) so that the Consumer’s full account number is NOT viewable on the receipt slip
Prohibited Actions:
Prohibit obtaining or using consumer credit report information except in connection with a permissible purpose, such as the collection of an account
prohibit the re-disclosure of medical information to any other person except as necessary to carry out the purpose for which the information was initially disclosed or otherwise permitted by statute, regulation, or order
prohibit the sharing of medical information with affiliates outside of certain defined exceptions
apply to the use of personal medical information in the context of consumer lending; specifically, the granting of credit, offering of forbearance programs, and noting of the account
The FACT Act requires that, if Attorney is notified of any information relating to an account that may reflect that an account has fraudulent activity or may be the result of identity theft, the Attorney is required to notify the client of the potential fraud/identity theft and, upon the customer’s request, provide account documents to the customer that the Attorney would normally provide to a customer.
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3. Citi Fraud v. Identity Theft
Citi defines fraud as identity theft or unauthorized charges.
Citi is legally required to investigate all fraud allegations made to it or its attorneys
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4. Fraud Allegations A fraud allegation exists when the customer says
This is not my account or I did not apply (identity theft)
I did not make or authorize the charge or charges (unauthorized charges)
For allegations of fraud, the vendor should do the following:
Complete as much of the “Citi Recovery Fraud Handling Form” as possible.
Once the customer has claimed fraud the Firm has 10 business days in which to forward documentation completed and obtained to Citi.
Collection efforts must cease until investigation is completed.
Forward any correspondence that has been received along with the “Citi Recovery Fraud Handling Form” to Citi at the address below using a nationally recognized courier to “overnight” the forms and documents.
Citibank, N.A. ATTN: RFCC GROUP, NW Ambassador Dr. 4th Floor, Kansas City, MO 64153
Or fax the documentation to: (877) Attn: RFCC (Recovery Fraud Claim Coordinator)
Citi will complete its investigation within 60 days.
Note: The Firm is required to stay all legal proceedings until the fraud investigation decision is communicated.
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5. Product Specific Requirements
Citi Mortgage:
Notify your Litigation processor of the claim and update VendorScape.
Citi Financial:
to or overnight the form and supporting documents to: Compliance Program Office Citi 6400 Las Colinas Blvd. Irving, TX Mail Stop CC3-92
 Business Banking:
Send the form through Secure to .
 Student Loans:
If a borrower / cosigner allege fraud/unauthorized use at any stage of the litigation process, Firms must send out a Citibank Student Loan Fraud Affidavit to the borrower or cosigner. 
Once the Fraud Affidavit has been completed and returned, the account will need to be reviewed by Student Loans - Collections to determine if fraud is actually involved before the Firm can proceed with litigation or return the account. 
The Fraud Affidavit must be sent via Secure to the Support Unit for investigation.  During the investigation the Firm must return the account to Student Loans - Collections. 
Macy’s:
Send the form via fax to the Macy’s Support Unit
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6. Questions?