1. Identity Theft Red Flags and Address Discrepancies Joint Notice of Proposed Rulemaking October 12, 2006 AIIM of Wisconsin

3. ID Theft Red Flags & Address Discrepancies FIL-64-2006 & other agency issuances FIL-64-2006 & other agency issuances FACTA – Sections 114 & 315 FACTA – Sections 114 & 315 Notice of Proposed Rule Making - comment period closed Sept. 18 Notice of Proposed Rule Making - comment period closed Sept. 18 36 comments – FDIC; approximately equal number for the other agencies 36 comments – FDIC; approximately equal number for the other agencies

4. ID Theft Red Flags & Address Discrepancies Written ID Theft Prevention Program – at least for FIs Written ID Theft Prevention Program – at least for FIs Appendix to the Regulation – has 31 enumerated ID Theft Red Flags (RF) > program to respond to each and systems in place to address; ie credit report with fraud alert > the person may/not be the owner of the account => system in place to validate the owner or pretender Appendix to the Regulation – has 31 enumerated ID Theft Red Flags (RF) > program to respond to each and systems in place to address; ie credit report with fraud alert > the person may/not be the owner of the account => system in place to validate the owner or pretender if RF kicked out – must demonstrate/prove not applicable if RF kicked out – must demonstrate/prove not applicable address change > within 30 days; not to issue the card unless confirms that someone is authentic. To avoid mail re-direct scam. [mandated by statute] address change > within 30 days; not to issue the card unless confirms that someone is authentic. To avoid mail re-direct scam. [mandated by statute] Address discrepancies – by credit report vs the other address shown. FI must take additional steps to validate the ID of owner Address discrepancies – by credit report vs the other address shown. FI must take additional steps to validate the ID of owner FI must report back to credit reporting agency and reasons believed the address is valid FI must report back to credit reporting agency and reasons believed the address is valid

5. ID Theft Red Flags & Address Discrepancies

8. Thank You! L. Bruce Finn bfinn@fdic.gov IT Examiner Division of Supervision and Consumer Protection, Chicago Region

9. Questions?