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os1. <br />s <br />f. A person fails to provide complete personal identifying <br />information on an application when reminded to do so. <br />g. A person's identifying information is not consistent with the <br />information that is on file for the customer. <br />5. Suspicious Activity of Unusual Use of an Account. The following are <br />indications that persons may be attempting to create or use fictitious <br />accounts. Other activities may occur that are also breaches that are <br />not included in this listing. <br />a. Change of address for an account followed by a request to <br />change the account holder's name. <br />b. Payments stop on an otherwise consistently up-to-date account. <br />c. Account used in a way that is not consistent with prior use. <br />(example: very high activity) <br />d. Mail sent to the account holder is repeatedly returned as <br />undeliverable. <br />e. Notice to the County that a customer is not receiving mail sent <br />by the County. <br />f. Notice to the County that an account has unauthorized activity. <br />g. Breach in the County's computer system security. <br />h. Unauthorized access to or use of customer account <br />information. <br />6. Alerts from Others. Notice to the County from a customer, identity <br />theft victim, law enforcement or other person that is has opened or is <br />maintaining a fraudulent account for a person engaged in Identity <br />• <br />Theft. An example of an alert could be a "notice of address <br />discrepancy" from a nationwide consumer reporting agency (NCRA). <br />(b) Step 2. Detection of Red Flags. <br />1. New Accounts. In order to detect any of the red flags identified <br />above associated with the opening of a new account, employees shall <br />take the following steps to obtain and verify the identity of the person <br />opening the account: <br />a. Require certain identifying information such as name, date of <br />birth residential or business address, principal place of <br />business for an entity, driver's licenses or other identification. <br />b. Verify the customer's identity (for instance, review a driver's <br />license or other identification card). <br />c. Review documentation showing the existence of a business <br />entity. <br />d. Independently contact the customer if the application is not <br />made in person by the customer. <br />• <br />Identity Theft/Red Flag Rules Page 7 <br />