Alerts, Notifications, or Warnings from a Consumer Reporting Agency
  • A fraud or active duty alert is included with a consumer report
  • A consumer reporting agency provides a notice of credit freeze in response to a request for a consumer report
  • A consumer reporting agency provides a notice of address discrepancy, as defined in 41.82(b) of the Final Rules for Identity Theft Red Flags and Address Discrepancies Under the Fair and Accurate Credit Transactions Act of 2003, as outlined in the 11/19/07 Federal Register
  • A consumer report indicates a pattern of activity that is inconsistent with the history and usual pattern of activity of an applicant or customer, such as
    • A recent significant increase in the volume of inquiries
    • An unusual number of recently established credit relationships
    • A material change in the use of credit, especially with respect to recently established credit relationships
    • An account that was closed for cause or identified for abuse of account privileges by a financial institution or creditor.
Suspicious Documents
  • Documents appear to have been altered or forged
  • The photograph or physical description on the identification is not consistent with the appearance of the applicant or customer presenting the identification
  • Other information on the identification is not consistent with information provided by the person opening a new covered account or customer presenting the identification
  • An application appears to have been altered or forged, or gives the appearance of having been destroyed and reassembled
Suspicious Personal Identifying Information
  • Personal identifying information provided is inconsistent when compared against external information sources used by the financial institution or creditor.
    • Examples: the address does not match any address in the consumer report; or the Social Security Number has not been issued, or is listed on the Social Security Administration's Death Master File
  • Personally identifying information provided by the customer is not consistent with other personal identifying information provided by the customer.
  • Personal identifying information provided is associated with known fraudulent activity as indicated by internal or third-party sources used by the institution
    • Examples: The address on an application is the same as the address provided on a fraudulent application; or the phone number on an application is the same as the number provided on a fraudulent application
  • Personal identifying information provided is of a type commonly associated with fraudulent activity as indicated by internal or third-party sources used by the institution.
    • Examples: The address on an application is fictitious, a mail drop, or a prison; or the phone number is invalid, or is associated with a pager or answering service
  • The SSN provided is the same as that submitted by other persons opening an account or other customers
  • The address or telephone number provided is the same as or similar to the account number or telephone number submitted by an unusually large number of other persons opening accounts or other customers
  • The person having or opening a covered account fails to provide all required personal identifying information on an application or in response to notification that the application is incomplete
  • Personal identifying information provided is not consistent with personal information that is on file with the institution
  • For financial institutions and creditors that use challenge questions, the person opening the covered account or the customer cannot provide authenticating information beyond that which generally would be available from a wallet or consumer report.
Unusual Use of, or Suspicious Activity Related to, the Covered Account
  • Shortly, following the notice of a change of address for a covered account, the institution receives a request for new, additional, or replacement cards, or the addition of authorized users on the account
  • The covered account is used in a manner commonly associated with known patterns of fraud.
    • Example: The customer fails to make the first payment or makes an initial payment but no subsequent payments
  • A covered account is used in a manner that is not consistent with established patterns of activity on the account.
    • Examples: Nonpayment when there is no history of late or missed payments; a material increase in use of available credit; a material change in purchasing or spending patterns; a material change in electronic fund transfer patterns in connection with a deposit account; or a material change in telephone call patterns in connection with a phone account (can be cellular or landline)
  • A covered account that has been inactive for a reasonably lengthy period of time is used (taking into consideration the type of account, the expected pattern of usage and other relevant factors)
  • Mail sent to customer is returned repeatedly as undeliverable although transactions continue to be conducted in connection with the customer's covered account
  • The institution is notified the customer is not receiving paper account statements
  • The institution is notified of unauthorized charges or transactions in connection with a customer's covered account
Notice from Customers, Victims of Identity Theft, Law Enforcement Authorities, or Other Persons Regarding Possible Identity Theft in Connection with Covered Accounts Held by the Institution