Identification of Relevant Red Flags

In order to identify relevant red flags, the University considers the types of covered accounts it offers and maintains, the methods it provides to open its covered accounts, the methods it provides to access its covered accounts, and its previous experience with identity theft. University personnel should be aware of and monitor for applicable red flags. The following is a categorized listing of relevant red flags that personnel should use as a guide in this process:

Suspicious Documents

1. Identification document or card that appears to be forged, altered or inauthentic.
2. Identification document or card on which a customer's photograph or physical description is not consistent with the person presenting the document.
3. Other document with information that is not consistent with existing customer information.
4. Application for service that appears to have been altered or forged.

Suspicious Personal Identifying Information

1. Identifying information presented that is inconsistent with other information the customer provides (example: inconsistent birth dates).
2. Identifying information presented that is not consistent when compared against external information sources used by the University (example: an address not matching an address on a credit report).
3. Identifying information provided is associated with known fraudulent activity as indicated by internal or third-party sources used by the University.
4. Identifying information provided is of a type commonly associated with fraudulent activity as indicated by internal or third-party sources used by the University.
5. Social security number presented that is the same as one given by another customer.
6. An address or phone number presented that is the same as one given by another customer.
7. A customer fails to provide complete personal identifying information on an application when reminded to do so.
8. A customer's identifying information is not consistent with the information that is on file for that customer.

Unusual Use of, or Suspicious Activity Related to, the Covered Account

1. Change of address for an account followed by a request to change the customer's name.
2. A credit account is used in a manner commonly associated with known fraud patterns (example: customer fails to make the first payment or makes an initial payment but no subsequent payments).
3. Account is used in a way that is not consistent with prior use.
4. Mail sent to the customer is returned repeatedly as undeliverable although transactions continue to be conducted in connection with the customer's covered account.
5. Notice to the University that a customer is not receiving mail sent by the University.
6. Notice to the University that an account has unauthorized activity.
7. Breach in the University's computer system security.
8. Unauthorized access to or use of student account information.

Alerts, Notifications or Warnings from a Consumer Reporting Agency

1. Report of fraud accompanying a credit report.
2. Notice or report from a credit agency or a credit freeze on an applicant.
3. Notice or report from a credit agency of an active duty alert for an applicant.
4. Receipt of a notice of address discrepancy in response to a credit report request.
5. Indication from a credit report of activity that is inconsistent with an applicant's usual pattern or activity.

Alerts from Others

1. Notice to the University from a customer, a victim of identity theft, a law enforcement authority, or any other person that has opened a fraudulent account for a person engaged in identity theft.