Identity Theft LIVE Teleconference
Overview:
Financial institutions and creditors will need to come into compliance with the final rules on Red Flags and Address Discrepancies by November 2008. The rules require financial institutions and creditors to develop and implement a written Identity Theft Prevention Program designed to detect, prevent, and mitigate identity theft.The Knowledge Congress is presenting a two-hour teleconference featuring a panel of experts who will express their views on the substantive aspects of these rules and provide guidance to financial institutions and creditors that may be affected by it.
Agenda:
SEGMENT 1:
<strong id="ep-name-of-speaker">Deborah Katz, Senior Counsel, Legislative and Regulatory Activities</strong>
<em id="ep-speaker-firm">Office of the Comptroller of the Currency</em>
- The written identity theft prevention program required by the rules;
- The special provision for card issuers that receive a notice of change of address followed by a
request for an additional card; and
- The requirements applicable to users of consumer reports that receive notices of address
discrepancies from a nationwide consumer reporting agency.
SEGMENT 2:
<strong id="ep-name-of-speaker">Pavneet Singh, Attorney, Division of Privacy and Identity Protection, Bureau of Consumer Protection</strong>
<em id="ep-speaker-firm">Federal Trade Commission </em>
- Who must comply with the red flags rules
- Identifying covered accounts and conducting a risk assessment
- The written id theft prevention program required by the rules
- The obligations of users of consumer reports who receive notices of address discrepancies from
nationwide CRAs
SEGMENT 3:
<strong id="ep-name-of-speaker">William H. Henley, Jr., Director, IT Risk Management, Office of Thrift Supervision</strong>
<em id="ep-speaker-firm">Office of Thrift Supervision </em>
FFIEC agencies and FTC released final rule in November 2007
– Implements sections 114 and 315 of the Fair and Accurate Credit Transactions Act of 2003
– Defined “red flag” as “a pattern, practice, or specific activity that indicates the possible existence
of identity theft”
– Agencies received 129 comment letters on proposal
– Complex interagency process with five federal depository institution regulators plus the FTC
– Rule applies to both regulated and non-regulated entities
Outlines steps financial institutions and creditors must take to administer the Program:
- Obtain approval of the initial written Program
- Ensure oversight of the development
- Implementation and overseeing service provider arrangements
- Train staff, as necessary, to effectively implement the Program
Implementation Challenges
- No “Silver Bullet” in Tackling ID Theft
- Flexibility is Important
- Fraudsters constantly change tactics and financial institutions need the flexibility to respond
to these changes
- A set list of red flags today may not be relevant in the future as fraudsters develop new tactics
- Large, complex financial institutions typically have multiple lines of business with responsibility
for managing fraud
- Variations in response programs & training programs
- Integration with Existing Programs
- Preamble of rule notes that an institution’s identity theft prevention program may incorporate or
cross-reference aspects of their security program and that an institution’s customer identification
program could be incorporated
- No requirement that identity theft program be identical across different lines of business
- Documentation of program
- Current processes already in place although many are not formally documented
- Lines of Business: “we know it when we see it”
- Vendor Management
- Outlining needs
- Negotiating contracts
- Impact on auditing programs (e.g., BITS Shared Assessments)
- Budget/Procurement Cycle
- 11/2008 deadline a challenge for some large firms to incorporate in technology budget cycle
- M&A impact
- Economic pressures
- Securing Board Approval
- Consistency in Regulatory Oversight
- Examination Procedures (in development):
- Impact of consumer compliance vs more risk-based IT driven process
SEGMENT 4:
<strong id="ep-name-of-speaker">Frank Barreca, CEO</strong>
<em id="ep-speaker-firm">speaker_company</em>
- The responsibility of consumers in the identity theft crisis.
- Data integrity – Lack of accuracy in public records and credit reporting data.
- Risk Based Data Analysis for Identity Theft.
- Consumer Advocacy Programs for Identity Theft - (Developing Consumer Advocacy Programs).
SEGMENT 5:
<strong id="ep-name-of-speaker">Catherine D. Meyer, Counsel</strong>
<em id="ep-speaker-firm">Pillsbury Winthrop Shaw Pittman LLP </em>
- Vendor management
• What is required in terms of:
› Vendor oversight including contracting with vendors
› Audit of vendors
› Use of vendors who perform services for other covered companies
› Detection response issues involving vendors
- Corporate approval of the policies and procedures that are developed, and risk potential issues
• Availability of enforcement actions by government, consumer, etc.
Who Should Attend:
- Chief Compliance Officers
- Chief Security Officers
- Chief Information Security Officers
- Audit Managers
- Risk Managers
- Chief Operations Officers
- Chief Privacy Officers
- Bank, Thrift and Credit Union Auditors
- Privacy & Data Protection Personnel
Deborah Katz is a senior counsel in the Legislative and Regulatory Activities Division of the Office of the Comptroller of …
Pavneet Singh is an attorney with the Division of Privacy and Identity Protection at the Federal Trade Commission. Her responsibilities …
Mr. Henley has spent his entire professional career as a financial institution regulator. Mr. Henley is the Director of IT …
Frank Barreca, a 25-year information technology veteran and recognized leader in the industry, provided the vision for the founding of …
Catherine D. Meyer has been Counsel with Pillsbury Winthrop Shaw Pitman for the past three years after having been a …
Course Level:
Intermediate
Advance Preparation:
Print and review course materials
Method of Presentation:
On-demand Webcast (CLE)
Prerequisite:
NONE
Course Code:
87876
Total Credits:
2.0 CLE
Login Instructions:
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SPEAKERS' FIRMS:
Office of the Comptroller of the Currency
Federal Trade Commission
Office of Thrift Supervision
About Office of the Comptroller of the Currency
About Federal Trade Commission
About Office of Thrift Supervision
About GetYourIdentityBack.com, LLC
Website: https://www.getyouridentityback.com/
About Pillsbury Winthrop Shaw Pittman LLP
Website: https://www.pillsburylaw.com/