Red Flag Rules

Identity Theft Prevention Program

Purpose and Scope

To establish an Identity Theft Prevention Program designed to detect, prevent, and mitigate identity theft in connection with the opening of a covered account or an existing covered account and to provide continued administration of the Program in compliance with Federal Trade Commission (FTC) 16 C.F.R. Part 681.

Elements of the Program include:

  1. Identifying Covered Account Transactions / Requests.
  2. Identifying relevant Red Flags for the covered accounts.
  3. Detecting Red Flags.
  4. Responding appropriately to any Red Flags that are detected to prevent and mitigate identity theft.
  5. Ensuring the Program is updated periodically to reflect changes in risks.

Administration of the Program

VP of Business and Finance shall be responsible for the development, inplementation, oversight, and continued administration of the Program. Under the direction of the VP, the Compliance Officer in USU CARD shall be responsible for performing and conducting annual risk assessments, providing training, and reviewing and responding to indentity theft incidences.


Account -- A continuing relationship established by a person with a financial institution or creditor to obtain a product or service for personal, family, household, or business purposes. Account includes an extension of credit, such as the purchase of property or services involving a deferred payment, and a deposit account.

Card Issuer -- Financial institution or creditor that issues a debit or credit card.

Consumer Reporting Agency -- Entities that collect and disseminate information about consumers to be used for credit evaluation and certain other purposes.

Consumer Reports -- Any written, oral, or other communication of any information by a consumer reporting agency bearing on a consumer’s credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living.

Covered Accounts -- (1) An account that a financial institution or creditor offers or maintains, primarily for personal, family, or household purposes, that involves or is designed to permit multiple payments or transactions, such as a credit card account, mortgage loan, automobile loan, margin account, cell phone account, utility account, checking account, or savings account; and, (2) Any other account that the financial institution or creditor offers or maintains for which there is a reasonably foreseeable risk to customers or to the safety and soundness of the financial institution or creditor from identify theft, including financial, operational, compliance, reputation, or litigation risks.

Creditor -- Any person, corporation, government or governmental subdivision or agency, trust, estate, partnership, cooperative, or association who regularly extends, renews, or continues credit; any person who regularly arranges for the extension, renewal, or continuation of credit; or any assignee of an original creditor who participates in the decision to extend, renew, or continue credit.

Customer -- A person that has a covered account with a financial institution or creditor.

Debit Card -- Any card issued by a financial institution to a consumer for use in initiating an electronic fund transfer from the account of the consumer at such financial institution for the purpose of transferring money between accounts or obtaining money.

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

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