Red Flag Rules

There are 4 major areas to the Red Flag Rule Policy:

1. Detect - Recognize an identity theft
2. Prevent - Do not let anyone else use a stolen identity at your
    business.
3. Mitigate - Report the theft to the rightful owner, law enforcement,
    and/or credit reporting agency.
4. Address Discrepancy- If you pull a credit report the shows the
    address from (example a drivers license) then you must have in place
    a policy to how you will act on this.

There are 4 important steps you must take to protect yourself:

1. Policy- Develop a written policy and have it approved by the
    owner, partner, board of directors or general manager of the
    dealership.
2. Train- Inform your employees about the new policy and how to
    comply with it.
3. Implement- To put in place your program to Detect, Prevent,
    Mitigate, and Address Discrepancy.
4. Audit and Review- Have an on going process to monitor and
    evaluate compliance with your program and to update if necessary.

The forms you will need to have are: (these forms can written by you the
owner of the business).

1. An employee acknowledgment- A form that the employee signs
    acknowledging that they understand the Red Flag Rules for your
    business.
2. A program coordinators form-
    A. Would include the date commence by the dealership.
    B. Coordinators responsibilities
    C. How the employees management will train the Red Flag
        Rules.

    D. Procedures on obtaining customer information and verifying
        their identities.
    E. Security standard that will be implemented in order to
        protect the customer’s information collected and maintained by
        your dealership.
    F. Discrepancies- How to deal with discrepancies the
        dealership encounters.
    G. The coordinator will also audit procedures as he/she deems
        necessary.
    H. A letter to service providers your business may come in
       contact with.
    I. The program coordinator will also have to deal with the
        address discrepancy and need a form that clarifies the
        procedures.