FDIC Releases FAQ on Red Flags

Yesterday, the FDIC issued a Financial Institution Letter (PDF) to address frequently asked questions regarding ID Theft Red Flags requirements. It’s mostly clarification for financial institutions, so there’s not a lot of “new” information in there. This is good because introducing new requirements at this stage could have resulted in additional costs for institutions that have already spent a lot of time and effort to establish their ID Theft Prevention Programs.  Still, if I were the CIO or compliance officer for a financial institution right now I’d pay very close attention to the answers in the FAQ and double-check any assumptions in my ID Theft Prevention Program to be sure they are in line with supervisory expectations.

Something else worth noting: According to the FIL, the FTC is will also be issuing an ID Theft Red Flags FAQ for all the other businesses under their jurisdiction.