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FACTA ID Theft Programs

FACTA ID Theft Programs. Auditing for Compliance Steven Nyren, CRCM Sheshunoff Consulting & Solutions BCAC Program – September 2008. ID Theft. “Obviously crime pays, or there’d be no crime” - G. Gordon Libby. The Challenge:. Each institution must develop and implement a program to:

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FACTA ID Theft Programs

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  1. FACTA ID Theft Programs Auditing for Compliance Steven Nyren, CRCM Sheshunoff Consulting & Solutions BCAC Program – September 2008

  2. ID Theft “Obviously crime pays, or there’d be no crime” - G. Gordon Libby

  3. The Challenge: Each institution must develop and implement a program to: • detect • prevent, and • mitigate identity theft

  4. IDENTITY THEFT PROGRAMS THE $100,000 QUESTION: • How do we know we’ve accomplished our goal?

  5. IDENTITY THEFT PROGRAM Ways to validate your program: • Monitoring • Audit

  6. Monitoring Use of Periodic Reviews: • Monitoring Checklists, where applicable • Testing to confirm compliance • Performed by line unit and/or compliance professional • Object is to identify and resolve issues before an audit or exam

  7. Validating the Program Auditing • More detailed scope and less frequent than monitoring • Independent perspective • May be conducted by Internal auditor and/or outside auditor or other qualified third party

  8. Auditing for Compliance • Process Documentation • Risk Assessment • Controls • Response Program • Training • Administration

  9. RED FLAG CHECK UP Are you ready for the examiners? • Is the Program fully documented? • Does it make sense? • Does practice match policy? • Is it effective?

  10. Risk Assessment • Does it consider? • Methods of opening Covered Accounts • Methods of accessing Covered Accounts • The Bank’s history with identity theft • Current fraud controls • Inherent and residual risks • The Bank’s overall ID Theft risk

  11. Controls • Are controls adequately documented? • Are all applicable red flags addressed? • Are they working as intended?

  12. Response Program • Is the method of documenting response actions to red flag incidents adequate? • What is management’s oversight method – centralized; department level? • Are the responses adequate?

  13. Training • Was it comprehensive? • Has it been documented? • Has it been completed?

  14. Resources • Regulatory Guidance • Industry Websites (Bankersonline.com, ABA.com, etc.) • Seminars and webinars

  15. Can It All Be Done? “Energy and persistence conquer all things.” - Benjamin Franklin

  16. Conclusion • Questions?

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