Planning on feeding an army? I asked when I spotted seven boxes of spaghetti noodles on my friend's kitchen counter. No, he laughed, we just keep forgetting to check what we already have before we go shopping. At this, his wife opened the pantry to reveal five large jars of jalapeno peppers. It's a mistake we keep making, she said, rolling her eyes. It occurred to me that the pasta and peppers scenario could be occurring in financial institutions today. In the rush to develop a compliance program for the newly passed FACT Act Red Flag and Address Discrepancy Rules, the compliance task force may inadvertently overlook some of the items they already have on the shelf. Many of the solutions financial institutions currently use to open new accounts and protect existing accountholders can be included as components of the financial institutions' Identity Theft Programs under the Red Rags Rule.
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