Presentation Pointers

The following is a summary of Red Flag Categories and examples drawn from a fair and accurate credit as the Act of 2003, Appendix J Part IIB and Appendix A of J. This will form the basis of our Compliance Management Program.

Understanding this is crucial for the development of an effective program of Red Flag to your car dealership. Yes, it is very boring, do not read while driving.

Categories of red flags:

I. alarm, alarms, or otherwarnings received from consumer reporting agencies or service providers, such as fraud detection services;

a. A fraud or active duty alert is included in a report of consumers.

b. A consumer reporting agency provides a notice of the claim block in response to a request for a report of consumers.

c. A consumer reporting agency provides a notice of address discrepancy, as defined in § 334.82 (b) of the framework between authorities.

d. One report indicates a pattern of consumeractivity that is incompatible with the history and usual pattern of activity of a candidate or client, such as:

I. STRENGTHENING A recent and significant scope of the investigations;

ii. An unusual number of recently established credit relationships;

III.A significant change in the use of credit, with particular reference to credit reports of new constitution;

iv. An account was closed for cause or identified for abuse of account privileges by a financial institutionor creditor.

II. The presentation of suspicious documents

a. identification documents appear to be altered or falsified.

b. The photograph or physical description on the identification is not consistent with the appearance of the applicant or customer presenting the identification.

C. Further information on identification is not consistent with the information that the person opening a new covered account or customer presentingidentification.

d. Further information on identification is not consistent with information readily available on file with the financial institution or creditor, such as signing a card or a check recently.

e. The question seems to be altered or forged, or gives the appearance of having been destroyed again.

III. Suspicious Personal Identifying Information

a. Personal data is not consistent with theexternal information sources used by the financial institution or creditor. Eg

i. The address does not match an address in the consumer reports, or

ii. The Social Security Number (SSN) has not been issued or are listed on the Social Security Administration's Death Master File.

iii. Personal information that the customer is not consistent with other personal information to the customer. For example, there is a shortage ofcorrelation between the SSN range and date of birth.

b. The personal data associated with known fraudulent activity as indicated by internal or third-party sources used by a financial institution or creditor. Eg

i. The address on an application is the same as the address of a fraudulent application or

ii. The telephone number of an application is the same as the number provided on a fraudulent application.

c. Personalidentifying information is of a type usually associated with fraudulent activity as indicated by internal or third-party sources used by a financial institution or creditor. Eg

i. The address on an application fictitious, a mail drop or prison, or

ii. Phone number is invalid or is connected to a pager or telephone service.

d. The SSN provided is the same as those adopted by other persons opening an account or other customers.

e.address or phone number provided, the same or similar to the account number or telephone number submitted by an unusually large number of other persons opening accounts or other customers.

b. The person opening the account or the customer, which fails to provide any personal information needed for an application or in response to the notice that an application is incomplete.

g. Personal data is not consistent with personalidentifiable information on file with the bank or creditor.

h. For financial institutions and creditors that use challenge questions, can open the account covered or client authentication information beyond that will be available from a wallet or consumer report no.

IV. Use of unusual or suspicious activity in connection with the Covered Account

A. Immediately after the notice of change of address for a decreaseArticle Theinstitution or creditor receives a request for a new card, additional or replacement or a cell phone, or with the addition of authorized users on the account.

b. A new revolving credit account is used so commonly associated with known patterns of fraud patterns. Eg

a. Most of available credit used for cash withdrawals or products that are readily convertible into cash (eg, electronic equipment and jewelry), or

ii. Client failsmake the payment before or makes an initial payment, but no further payments.

c. An account of which is not used in accordance with established activity patternsof the account. There is, for example:

i. Failure to pay when there is a history of late payments or missed

ii. A significant increase in the use of credit;

iii. An important change for the purchase or consumption patterns;

iv. Significant change in electronic fund transfer patternsconnection with a savings account.

v. a material change in telephone call patterns in connection with an account of mobile telephony.

d. An account object that has been inactive for a relatively long period of use (in terms of type of account, the expected pattern of usage and other relevant factors).

E. Mail sent to customer repeatedly returned as undeliverable although transactions continue to perform in connection with the customercovered account.

f. The financial institution or creditor is notified that the client can not receive paper statements.

g. The financial institution or creditor notified of unauthorized charges or

transactions associated with a customer's account is covered.

VI. Rating of customers, victims of identity theft, law enforcement, or other persons with the possibility of identity theft in connection with a Covered Financial AccountInstitution or creditor

a. The financial institution or creditor is notified by a customer, a victim of identity theft, a police officer or any person who is a fraudulent account opened for a person who is involved in identity theft.

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