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<br />6.38 <br />ATTACHMENT 2 Page 5 <br /> <br />Identity Theft Prevention Program <br /> <br />PURPOSE <br /> <br />This document was created in order to comply with regulations issued by the <br />Federal Trade Commission (FTC) as part of the implementation of the Fair and <br />Accurate Credit Transaction (FACT) Act of 2003. The FACT Act requires every <br />financial institution and creditor to establish an Identity Theft Prevention Program <br />to provide for detection of and response to specific activities (red flags). <br /> <br />The City of Redwood City bills and collects payments for utility services in arrears <br />and thus is considered a creditor under the FACT Act. <br /> <br />The FTC regulations require that the program must: <br /> <br />1. Identify relevant red flags and incorporate them into the program <br /> <br />2. Identify ways to detect red flags <br /> <br />3. Respond appropriately to any red flags that are detected <br /> <br />4. Ensure the program is updated periodically, to reflect changes in risks to <br />customers or to the safety and soundness of the creditor from identity theft <br /> <br />5. Include a process for administration and oversight of the program <br />