Identify Red Flags for Covered Accounts Sample Clauses

Identify Red Flags for Covered Accounts. A Red Flag is a pattern, practice, or specific activity that indicates the possible risk of identity theft. (See below for detailed definitions used in the Program.) Pxxxxxx must develop a written Program that puts in place reasonable policies and procedures to identify relevant Red Flags and incorporate them into the Program. To identify a “relevant Red Flag,” the institution should consider: (1) the types of covered accounts it offers or maintains; (2) the methods it employs for opening and providing continued access to its covered accounts; and (3) its previous experiences with identity theft. The FTC’s guidelines offer 31 examples of Red Flags, broken down into five categories. These categories include: (1) warnings from consumer reporting agencies or service providers; (2) presentation of suspicious documents; (3) presentation of suspicious Identity Theft Prevention Policy and Program personal identifying information; (4) unusual or suspicious account-related activity; and (5) notice from persons such as customers or law enforcement authorities regarding possible identity theft in connection with an institution’s covered accounts. According to the FTC, no particular Red Flag must be included in the Program and the required identification of Red Flags is to come from Pxxxxxx’s own risk assessment. Prosper, however, will include the examples of Red Flags listed in the FTC’s guidelines in its list of relevant Red Flags unless it concludes that the particular Red Flag is inapplicable to Prosper’s business.