HBP Part 19.5.2. Identity Theft Program Guidelines

Handbook of Business Procedures

Date published: November 11, 2013
Last revised: June 25, 2014
Issued by: Risk Management

19.5.2 IDENTITY THEFT PROGRAM GUIDELINES

Red flags are suspicious patterns or practices, or specific activities that indicate the possibility that identity theft may occur. All University of Texas at Austin departments must follow the Identity Theft Program’s guidelines for identifying and responding to the red flags listed below.

1. Alerts, Notifications, or Warnings from Consumer Protection Agencies

Red Flag Required Response/Action
1. A fraud or active duty alert accompanies a consumer report requested by the university. 1. Verify activity reported with applicant.
2. If verified, proceed with evaluation of applicant based on consumer report received.
3. If unable to verify, do not use this report in evaluating applicant - no further action required.
2. A notice of a credit freeze is received in response to a request for a consumer report. 1. Verify activity reported with applicant.
2. If verified, proceed with evaluation of applicant based on consumer report received.
3. If unable to verify, do not use this report in evaluating applicant-no further action required.
3. A notice of address discrepancy is received in response to a request for a consumer report. 1. Compare reported address with that provided by applicant and, if necessary, contact the applicant to verify.
2. If address has been verified, report to credit report agency.
3. If unable to determine relationship between the applicant and the notice, do not use the report to evaluate the applicant and notify the applicant. No further action required.

 

2. Suspicious Documents

Red Flag Required Response/Action
1. Identification documents or card provided appears to have been altered or forged. 1. Retain identification, notify departmental management, and contact the Fraud Hotline for assistance.
2. If identification appears fraudulent, report to UTPD.
2. Identification documents or card provided on which the photograph or physical description is not consistent with the appearance of the customer presenting the documents. 1. Retain identification, notify departmental management, and contact the Fraud Hotline for assistance.
2. If identification appears fraudulent, report to UTPD.
3. Identification documents or card provided on which other identifying information is not consistent with information provided by customer or other readily accessible information that is on file (e.g., birth date doesn't match appearance of customer). 1. Retain identification, notify departmental management, and contact the Fraud Hotline for assistance.
2. If identification appears fraudulent, report to UTPD.
4. Request for information, applications, or other documents presented appear to have been altered or forged, or gives the appearance of having been destroyed and reassembled. 1. Retain identification, notify departmental management, and contact the Fraud Hotline for assistance.
2. If identification appears fraudulent, report to UTPD.

 

3. Suspicious Personal Identifying Information

Red Flag Required Response/Action
1. Identifying information is inconsistent with other external information sources (e.g., an address that does not match the address printed on a loan application). 1. Inspect identification and compare with other external information sources.
2. Retain identification, notify departmental management, and contact the Fraud Hotline for assistance.
3. If information appears fraudulent, report to UTPD.
2. Identifying information is inconsistent with other information provided by the customer (e.g., inconsistent birth dates). 1. Inspect identification and compare with student records.
2. Retain identification, notify departmental management, and contact the Fraud Hotline for assistance.
3. If information appears fraudulent, report to UTPD.
3. Identifying information is associated with known fraudulent activity (e.g., address or phone number being used is also known to be associated with a fraudulent application). 1. Inspect identification and compare with documentation indicating fraudulent activity.
2. Retain identification, notify departmental management, and contact the Fraud Hotline for assistance.
3. If information appear fraudulent, report to UTPD.
4. Identifying information is of the type commonly associated with fraudulent activity (e.g., fictitious address or invalid phone number). 1. Inspect identifying information.
2. Retain identification, notify departmental management, and contact the Fraud Hotline for assistance.
3. If information appear fraudulent, report to UTPD.
5. Social Security Number (SSN) or UT EID is the same as that submitted by another customer. 1. Inspect identifying information.
2. Retain document provided, request to see student's SSN card, UT ID card, or driver's license and retain a copy if discrepancy is not resolved.
3. Do not provide any services until identity is proven. Place hold on original customer who provided the duplicate ID if identity is proven. Notify management for assistance.
4. If information appears fraudulent, report to UTPD.
6. Address or phone number is the same as that presented by an unusually large number of other customers. 1. Request and inspect identifying documents to confirm information provided.
2. If information appears fraudulent, report to UTPD.
7. A customer fails to provide all of the required personal identifying information on an application or in response to notification that the application is incomplete. 1. Do not provide any services or award aid until application is complete.
2. If information appears fraudulent, report to UTPD.
8. Identifying information is inconsistent with internal information sources on file. 1. Inspect identifying information.
2. Retain identification, notify departmental management, and contact the Fraud Hotline for assistance.
3. If information appear fraudulent, report to UTPD.
9. Customer cannot provide information in response to challenge questions beyond that which generally would be available from a wallet or consumer report. 1. Do not provide any services, do not reset PINs.
2. If situation appears fraudulent, report to UTPD.

 

Unusual Use of or Suspicious Activity Related to Covered Accounts

Red Flag Required Response/Action
1. Change of address for an account that is followed shortly by request for a name change. 1. Request official documentation reflecting name change (e.g., court order, marriage certificate, etc.) and compare with photo identification.
2. Verify change of address previously submitted.
2. Mail sent to customer is returned repeatedly although transactions continue to be conducted. 1. Verify address information with customer and ensure listed addresses are active.
2. If address on file was not entered by customer, notify management for assistance.
3. If situation appears to be fraudulent, contact UTPD.
3. Customer notifies university via phone, email, or in person that he is not receiving mail. 1. Notify departmental management for assistance and investigation.
2. If situation appears fraudulent, report UTPD.

 

5. Notice from Customers, Victims of Identity Theft, Law Enforcement, or Others Regarding Possible Identity Theft

Red Flag Required Response/Action
1. Customer notifies university via phone, email, or in person that an account has been opened fraudulently or is being maintained by the university for a person engaged in identity theft. 1. Notify departmental management for assistance.
2. Place a hold on the account and contact UTPD and request officer assistance.
3. If situation appears fraudulent, report to UTPD.
2. Customer reports via phone, email, or in person receiving a bill for another individual or for a service that the customer denies receiving. 1. Notify departmental management for assistance and investigation.
2. If situation appears fraudulent, report to UTPD.
3. Customer reports via phone, email, or in person that their personal information has been compromised. 1. Notify departmental management for assistance and investigation.
2. If situation appears fraudulent, report to UTPD.

 

6. Other

Red Flag Required Response/Action
1. Customer reports via phone, email, or in person that an unauthorized charge has occurred to the bank account information on My Bank Information. 1. Notify departmental management and inactivate bank on My Bank Information.
2. If situation appears fraudulent, report to UTPD.
2. Customer reports via phone, email, or in person that an unauthorized change has occurred to student address information in the university registration system. 1. Notify departmental management and inactivate address entry.
2. If situation appears fraudulent, report to UTPD.

 

 

Part 19. Risk Management - Table of Contents