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					Oakland University Student Business Services Identity Theft Red Flag Policy

Red Flags Procedures
Alerts, Notifications or Warnings from a Consumer Reporting Agency:
1. A fraud or active duty alert is included with a consumer report. 2. A consumer reporting agency provides a notice of credit freeze in response to a request for a consumer report. 3. A consumer reporting agency provides a notice of address discrepancy, as defined in §681.1(b) of this part. 4. A consumer report indicates a pattern of activity that is inconsistent with the history and usual pattern of activity of an applicant or customer, such as: a. A recent and significant increase in the volume of inquiries; b. An unusual number of recently established credit relationships; c. A material change in the use of credit, especially with respect to recently established credit relationships; or d. An account that was closed for cause or identified for abuse of account privileges by a financial institution or creditor.

Collections Skip-Trace Reporting:  If we receive notification from a collection agency that a student’s address differs from what was present in Banner, this is a red flag. o Send an e-mail to current students:  tell them we received a change of address notification  request confirmation of the address change, and  direct them to SAIL to update the information in Banner, if applicable o Send a letter to non-registered students at the address on file in Banner and the address provided by the agency:  tell them we received a change of address notification  request confirmation of the address change, and  direct them to SAIL to update the information in Banner, if applicable SEE AUTOMATIC ADDRESS E-MAIL NOTIFICATION PROCESS BELOW Suspicious Documents
5. Documents provided for identification appear to have been altered or forged. 6. The photograph or physical description on the identification is not consistent with the appearance of the applicant or customer presenting the identification. 7. Other information on the identification is not consistent with information provided by the person opening a new covered account or customer presenting the identification. 8. Other information on the identification is not consistent with readily accessible information that is on file with the financial institution or creditor, such as a signature card or a recent check. 9. An application appears to have been altered or forged, or gives the appearance of having been destroyed and reassembled.

Photo ID: If you are handed photo id to process a check or to confirm that the person you are talking with is the student:  Compare the picture on the id with the person in front of you, if the picture is substantially different, this is a red flag. o Ask for alternative photo id.

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Oakland University Student Business Services Identity Theft Red Flag Policy If the name on a check (received or distributed) and the name on the photo id are the same, compare the address listed on both documents. If the addresses are different, this is a red flag. o Flip the photo id and verify there is a change of address sticker on the back. o If the person is the student, look in Banner to see if both addresses are present. o Compare the address on the photo id to Banner to verify that the address on the photo id is the same as the address on file If the check is signed at the window and the name matches the name on the photo id, compare the signatures of both documents, if they are substantially different, this is a red flag. o Ask for alternative photo id. If the photo id appears altered or forged, this is a red flag. o Contact a supervisor. o Need to create a training process on identifying potential forgeries.

Direct Deposit Forms:  To identify if fraud is being attempted, compare the address on the cancelled or voided check to the student’s address in Banner (Use customer service database to access this information quickly.) If there is a difference, this is a red flag. o Consider moving this activity online for greater authentication.  NOTE: eRefunds may not be able to be used since we use multiple detail codes. o Add a checkbox to direct deposit form: Address verified in Banner Student Consent for Release of Records, Direct Deposit Forms:  If the form appears to have been altered or forged, this is a red flag. o Return the form to the student using the address on file in Banner with a note explaining that the form appears to have been altered and request a new form be submitted. Credit Cards:  Compare the signature on a credit card receipt with the signature on the back of the credit card (if the card is not signed, compare drivers license signature to credit card receipt signature); if they appear different, this is a red flag. . o Ask the person for photo id to verify the signature. o SBS requires photo id for all transactions. Vouchers:  SSN’s on vouchers or rosters received on file in Banner, this is a red flag. o Third party payers (such as State of Michigan) still including SSN’s on vouchers need to be notified to stop this practice. o Consider not accepting vouchers with SSN’s included. Void & Re-issue Refund Check Request:  Compare the address listed on a void and re-issue request to the address listed in Banner, if the address doesn’t match or the address in Banner was recently changed, this is a red flag. D:\Docstoc\Working\pdf\84fde427-382a-4385-8cae-f8856363f38b.doc 10/15/2008

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Oakland University Student Business Services Identity Theft Red Flag Policy Require students to complete the void and re-issue form in person so we can verify their address with photo id. The photo ID verifies the change of address. (if this is implemented the red flag would change to: address on photo id not matching Banner or address requested.) Add checkbox to void / reissue form: Address verified to Banner / Drivers License.

Suspicious Personal Identifying Information
10. Personal identifying information provided is inconsistent when compared against external information sources used by the financial institution or creditor. For example: a. The address does not match any address in the consumer report; or b. The Social Security Number (SSN) has not been issued, or is listed on the Social Security Administration's Death Master File. 11. Personal identifying information provided by the customer is not consistent with other personal identifying information provided by the customer. For example, there is a lack of correlation between the SSN range and date of birth. 12. Personal identifying information provided is associated with known fraudulent activity as indicated by internal or third-party sources used by the financial institution or creditor. For example: a. The address on an application is the same as the address provided on a fraudulent application; or b. The phone number on an application is the same as the number provided on a fraudulent application. 13. Personal identifying information provided is of a type commonly associated with fraudulent activity as indicated by internal or third-party sources used by the financial institution or creditor. For example: a. The address on an application is fictitious, a mail drop, or a prison; or b. The phone number is invalid, or is associated with a pager or answering service. 14. The SSN provided is the same as that submitted by other persons opening an account or other customers. 15. The address or telephone number provided is the same as or similar to the account number or telephone number submitted by an unusually large number of other persons opening accounts or other customers. 16. The person opening the covered account or the customer fails to provide all required personal identifying information on an application or in response to notification that the application is incomplete. 17. Personal identifying information provided is not consistent with personal identifying information that is on file with the financial institution or creditor. 18. For financial institutions and creditors that use challenge questions, the person opening the covered account or the customer cannot provide authenticating information beyond that which generally would be available from a wallet or consumer report.

Payment by check:  Compare the address on the check received for payment to the address on file in Banner. If the address is not the same, require the student to visit the kiosk and update their address in SAIL.  NOTE: third party checks cannot be verified. Change of address request:  If there is more than one address change for a student in the last 4 months, this is a red flag. o Send a letter to the all addresses changed within the preceding 4 months requesting confirmation. SEE RED FLAGS ADDRESS AUDIT PROCESS BELOW  If you receive a change of address to a PO Box or other non-physical location, this is a red flag. o In person, ask to see photo id and compare it to an address already in the system. 10/15/2008

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Oakland University Student Business Services Identity Theft Red Flag Policy o If on paper or online, send letters to both addresses requesting confirmation. Vendors send lists of students with address changes which are performed using vendor’s online system. If address updates are frequent for a given student, this is a red flag. o Send a letter to the last and newest address requesting confirmation.

Agency Referrals:  University Accounting Services Red Flag Procedures on file.  General Revenue Corporation Red Flag Procedures on file.  Williams & Fudge Corporation Red Flag Procedures on file.  TouchNet Position on Red Flag Procedures on file.  Vangent Red Flag Procedures on file. Unusual Use of, or Suspicious Activity Related to, the Covered Account
19. Shortly following the notice of a change of address for a covered account, the institution or creditor receives a request for a new, additional, or replacement card or a cell phone, or for the addition of authorized users on the account. 20. A new revolving credit account is used in a manner commonly associated with known patterns of fraud patterns. For example: a. The majority of available credit is used for cash advances or merchandise that is easily convertible to cash (e.g., electronics equipment or jewelry); or b. The customer fails to make the first payment or makes an initial payment but no subsequent payments. 21. A covered account is used in a manner that is not consistent with established patterns of activity on the account. There is, for example: a. Nonpayment when there is no history of late or missed payments; b. A material increase in the use of available credit; c. A material change in purchasing or spending patterns; d. A material change in electronic fund transfer patterns in connection with a deposit account; or e. A material change in telephone call patterns in connection with a cellular phone account. 22. A covered account that has been inactive for a reasonably lengthy period of time is used (taking into consideration the type of account, the expected pattern of usage and other relevant factors). 23. Mail sent to the customer is returned repeatedly as undeliverable although transactions continue to be conducted in connection with the customer's covered account. 24. The financial institution or creditor is notified that the customer is not receiving paper account statements. 25. The financial institution or creditor is notified of unauthorized charges or transactions in connection with a customer's covered account. Notice from Customers, Victims of Identity Theft, Law Enforcement Authorities, or Other Persons Regarding Possible Identity Theft in Connection With Covered Accounts Held by the Financial Institution or Creditor 26. The financial institution or creditor is notified by a customer, a victim of identity theft, a law enforcement authority, or any other person that it has opened a fraudulent account for a person engaged in identity theft.

Refund Check  If someone calls regarding not receiving a refund check, ask them what address the check should have been mailed to. If this address does not match the address in Banner, ask the caller for their previous address, if the previous address does not match an address in Banner, this is a red flag. o Ask the student to come in person to complete a void and re-issue form so we can verify address via photo id. D:\Docstoc\Working\pdf\84fde427-382a-4385-8cae-f8856363f38b.doc 10/15/2008

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Oakland University Student Business Services Identity Theft Red Flag Policy Audit student receiving refund checks for change of address and/or change in direct deposit form, if an address was changed within the last 30 days, this is a red flag. o Update refund process to include automated pull of address activity. o Send a letter to the last and newest address requesting confirmation.  In-person or online address changes  Hold check; watch disbursement regulations

Non-Payment of Account:  Students who fail to make payments are contacted via the due diligence process. o E-mail reminders are sent to the student. o After each semester, written reminders are sent to the student’s current address on file. o Phone contact is attempted with students who have not responded. o Students are referred to outside collection agency.  When a student claims to have not received past due notices, confirm with them the mailing address. If the address is correct in Banner, advise the student to contact his/her local post office for advice. If the address on Banner has never been the student's address, this is a red flag. o Advise the student to view his/her credit report and investigate possible identity theft. o Place a hold on the student account to appropriately document the account as being a potential identity theft. The hold will alert the employee to take special care in identifying the student in the future.

Notice from Customers, Victims of Identity Theft, Law Enforcement Authorities, or Other Persons Regarding Possible Identity Theft in Connection with Covered Accounts Held by the Financial Institution or Creditor
27. The financial institution or creditor is notified by a customer, a victim of identity theft, a law enforcement authority, or any other person that it has opened a fraudulent account for a person engaged in identity theft.

To assist in identifying activity regarding the student involved,  Place a hold on the account that flagged personnel in our office that take payment and generate overpayments to the fact that the student has a red flag.  Staff would take extra care when processing changes related to the account such as address changes, or void and reissue requests. Agency Referrals:  Should such an event occur, the agency will promptly notify affected clients and borrowers.  Place a hold on the account that flagged personnel in our office that take payment and generate overpayments to the fact that the student has a red flag.  Staff would take extra care when processing changes related to the account such as address changes, or void and reissue requests. SAIL SELF SERVICE ADDRESS UPDATES PROJECT – GO LIVE DATE 4/30/09 D:\Docstoc\Working\pdf\84fde427-382a-4385-8cae-f8856363f38b.doc 10/15/2008

Oakland University Student Business Services Identity Theft Red Flag Policy    Goal is to direct students to update their address on SAIL or require in person with photo. Special circumstance process needs to be developed to assist students who are not able to access SAIL to update their address online. Communication plan needs to be developed to notify faculty, staff and students o That the primary method of changing addresses for students in online through SAIL. o Who to contact if there is a special circumstance that needs to be addressed. o Who to contact if the student experiences difficulties updating their address online. Need to lock down access to updates; Student Business Services and the Registrar’s will coordinate a review of access to determine the validity of the access. The Billing and Collections area is the only area that will be allowed to make address changes in Banner effective with the SAIL Self Service implementation.

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SEE RED FLAGS ADDRESS AUDIT PROCESS BELOW   Student Business Services to develop a query from the SAIL self-service address change table or from SPRADDR activity date to identify frequent address changes. University Technology Services (UTS) will run the query and forward potential red flag account information to Student Business Services for follow-up.

AUTOMATIC ADDRESS E-MAIL NOTIFICATION PROCESS  Shared Data Committee and Red Flags Committee to create the process to identify the type of activity that would require an e-mail notification: o Exclude self-service and Clean Address updates????? File helpdesk ticket to implement a Workflow e-mail communication process.

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