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FACTA ID Theft Programs. Auditing for Compliance Steven Nyren, CRCM Sheshunoff Consulting & Solutions BCAC Program – September 2008. ID Theft. “Obviously crime pays, or there’d be no crime” - G. Gordon Libby. The Challenge:. Each institution must develop and implement a program to:

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facta id theft programs

FACTA ID Theft Programs

Auditing for Compliance

Steven Nyren, CRCM

Sheshunoff Consulting & Solutions

BCAC Program – September 2008

id theft
ID Theft

“Obviously crime pays, or there’d be no crime”

- G. Gordon Libby

the challenge
The Challenge:

Each institution must develop and implement a program to:

  • detect
  • prevent, and
  • mitigate identity theft
identity theft programs
IDENTITY THEFT PROGRAMS

THE $100,000 QUESTION:

  • How do we know we’ve accomplished our goal?
identity theft program
IDENTITY THEFT PROGRAM

Ways to validate your program:

  • Monitoring
  • Audit
monitoring
Monitoring

Use of Periodic Reviews:

  • Monitoring Checklists, where applicable
  • Testing to confirm compliance
  • Performed by line unit and/or compliance professional
  • Object is to identify and resolve issues before an audit or exam
validating the program
Validating the Program

Auditing

  • More detailed scope and less frequent than monitoring
  • Independent perspective
  • May be conducted by Internal auditor and/or outside auditor or other qualified third party
auditing for compliance
Auditing for Compliance
  • Process Documentation
  • Risk Assessment
  • Controls
  • Response Program
  • Training
  • Administration
red flag check up
RED FLAG CHECK UP

Are you ready for the examiners?

  • Is the Program fully documented?
  • Does it make sense?
  • Does practice match policy?
  • Is it effective?
risk assessment
Risk Assessment
  • Does it consider?
      • Methods of opening Covered Accounts
      • Methods of accessing Covered Accounts
      • The Bank’s history with identity theft
      • Current fraud controls
      • Inherent and residual risks
      • The Bank’s overall ID Theft risk
controls
Controls
  • Are controls adequately documented?
  • Are all applicable red flags addressed?
  • Are they working as intended?
response program
Response Program
  • Is the method of documenting response actions to red flag incidents adequate?
  • What is management’s oversight method – centralized; department level?
  • Are the responses adequate?
training
Training
  • Was it comprehensive?
  • Has it been documented?
  • Has it been completed?
resources
Resources
  • Regulatory Guidance
  • Industry Websites (Bankersonline.com, ABA.com, etc.)
  • Seminars and webinars
can it all be done
Can It All Be Done?

“Energy and persistence conquer all things.”

- Benjamin Franklin

conclusion
Conclusion
  • Questions?
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