Red Flag Guidelines Released!; Off to SF
Late Friday, the Fed released the interagency guidelines for the Identity Theft Red Flags and other regulations issued pursuant to the FCRA. You can access the Fed's Supervisory Letter, which has links to the exam procedures, here. I would expect NCUA to quickly push this out, but I figure that many of you would want this sooner rather than later.
There is a separate exam guideline for each component (Red Flags, Address Discrepancy, and Change of Address). The exam guidelines are not all that daunting. The Red Flags module is five pages long, and the exam procedures take up just two of those pages. But there is great information in there. For example...
Do you have to update your Red Flags ID Theft risk assessment each year? No. Just update it periodically, as needed.
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The Compliance Guy is off to San Francisco for our annual Regulatory Compliance Seminar. During the week, many, if not all, NAFCU compliance attorneys will be at the conference. If you need to reach us (NAFCU members), your best bet is to email us at compliance@nafcu.org. But please realize that response times may be a bit delayed. If you couldn't join us, think about next year, as Seminar will be held in Charleston, South Carolina.