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09/14/2009 ATTACHMENT 2 IDENTIFICATION OF RED FLAGS The guidelines published by the FTC include examples of red flags which fall into the five categories below: 1. Notifications and warnings from consumer reporting agencies or service providers 2. Suspicious documents 3. Suspicious personal identifying information 4. Suspicious account activity or unusual use of account. 5. Notice from customers, victims of identity theft, or law enforcement authorities Based on the FTC's FACT Act guidelines, the following red flags are applicable to administration of the City's utility accounts. 1. Suspicious Documents and Activities • The customer does not provide required identification information when attempting to establish a utility account or make a payment. • Documents provided for identification appear to have been altered or forged. • Information on the identification is not consistent with information provided by the customer. • A customer refuses to provide identification information when discussing an established utility account. • A person other than the account holder or co- applicant requests information or asks to make changes to an established utility account. 2. A customer notifies the Revenue Services Division of any of the following activities: • Utility statements are not being received • Unauthorized changes to a utility account • Unauthorized charges on a utility account • Fraudulent activity on the customer's bank account or credit card that is used to pay utility charges 3. The Revenue Services Division is notified by a customer, a victim of Identity Theft, or a member of law enforcement that a utilities account has been opened for a person engaged in Identity Theft. DETECTING AND RESPONDING TO RED FLAGS Red flags will be detected as Revenue Services Division employees interact with customers. An employee will be alerted to these red flags during the following processes: 14968 MUFF 205