Accounting Office

Red Flag Program

General

Identity theft, a fraud committed or attempted using the identifying information of another person without authority, is a growing problem within the United States and abroad.  According to the Federal Trade Commission (FTC), 9 million Americans have their identities stolen each year.  In response to this problem the FTC, in conjunction with other government entities, has established "Red Flag" rules from the Fair and Accurate Credit Transactions Act (FACTA) of 2003.  These rules require financial institutions and creditors that offer or maintain one of more covered accounts to develop and implement a written program that is designed to detect, prevent, and mitigate identity theft in connection with the opening of a covered account or any existing covered account.  Financial institutions and creditors are required to implement a Red Flag program by May 1, 2009.  As a "creditor" and in response to the risk posed to its students and staff, Willamette University adopts the following program.  The University has taken into consideration the size and complexity of its operations and the nature and scope of its activities in crafting this program.

Covered Account:
  1. An account primarily for personal, family, or household purposes, that involves or is designed to permit multiple payments or transactions; or,
  2. Any other account for which there is a reasonably foreseeable risk to customers or the safety and soundness of the financial institution or creditor from identity theft.

Creditor:  An entity who arranges for the extension, renewal, or continuation of credit, which in some cases could include third-party debt collectors.

Credit:  The right granted by a creditor to a debtor to defer payment of debt or to incur debt and defer its payment or to purchase property or services and defer payment therefore.

Customer:  Any person with a covered account with a creditor.

Service Provider: A person, or entity, that provides a service directly to the financial institution or creditor.

Definitions

Red Flag: A pattern, practice, or specific activity that indicates the possible existence of identity theft.

Identity Theft: A fraud committed or attempted using the identifying information of another person without authority.

Identifying Information: The FTC defines this term as "any name or number that may be used, alone or in conjunction with any other information, to identify a specific person, including":

  • Name
  • Social security number
  • Date of birth
  • State or government issued driver's license or identification number
  • Alien registration number
  • Government passport number
  • Employer or taxpayer identification number
  • Unique electronic identification number
  • Computer's internet protocol address or routing code