10.20.050 Identifying red flags.
Each numbered item listed under subsections (a) through (e) of this section represents a red flag for purposes of the program.
(a) 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.
(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:
(i) A recent and significant increase in the volume of inquiries;
(ii) An unusual number of recently established credit relationships;
(iii) A material change in the use of credit, especially with respect to recently established credit relationships; or
(iv) An account that was closed for cause or identified for abuse of account privileges by a financial institution or creditor.
(b) Suspicious Documents.
(1) Documents provided for identification appear to have been altered or forged.
(2) The photograph or physical description on the identification is not consistent with the appearance of the applicant or customer presenting the identification.
(3) Other information on the identification is not consistent with information provided by the person opening a new covered account or the customer presenting the identification.
(4) Other information on the identification is not consistent with readily accessible information that is on file such as a signature card or a recent check.
(5) An application appears to have been altered or forged, or gives the appearance of having been destroyed and reassembled.
(6) Bank check appears to have been previously used.
(7) Starter check with no name/address printed.
(8) Application with no voided check (bank information printed by customer).
(9) Receipt of voided check with no signature.
(10) Application signed by someone other than customer on WSSC account.
(11) Bank information indicated for someone other than name on WSSC account.
(12) Application indicating different mailing address than service address.
(13) Request to debit monthly on a quarterly billed account.
(14) Bank error report indicating “no account/cannot locate” or “bank account closed.”
(15) Previous fraudulent/theft noted on account the customer is applying for.
(c) Suspicious PII.
(1) PII provided by the customer is inconsistent when compared against external information sources. For example:
(i) The address does not match any address in the consumer report; or
(ii) The Social Security Number (SSN) has not been issued, or is listed on the Social Security Administration’s Death Master File.
(2) PII provided by the customer is not consistent with other PII provided by the customer. For example, there is a lack of correlation between the SSN range and date of birth.
(3) PII is associated with known fraudulent activity as indicated by internal or third-party sources used by the Commission.
For example:
(i) The address on an application is the same as the address provided on a fraudulent application; or
(ii) The phone number on an application is the same as the number provided on a fraudulent application.
(4) PII provided is of a type commonly associated with fraudulent activity as indicated by internal or third-party sources used by the Commission.
For example:
(i) The address on an application is fictitious, a mail drop, or a prison; or
(ii) The phone number is invalid, or is associated with a pager or answering service.
(5) The SSN provided is the same as that submitted by other persons opening an account or other customers.
(6) 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.
(7) The person opening the covered account or the customer fails to provide all requested PII on an application or in response to notification that the application is incomplete.
(8) PII provided by the customer is not consistent with PII that is on file with the Commission.
(9) If challenge questions are used, 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.
(d) Unusual Use of, or Suspicious Activity Related to, Covered Accounts.
(1) A new account is used in a manner commonly associated with known patterns of fraud patterns.
For example: The customer fails to make the first payment or makes an initial payment but no subsequent payments.
(2) A covered account is used in a manner that is not consistent with established patterns of activity on the account.
For example:
(i) Nonpayment when there is no history of late or missed payments;
(ii) A material change in electronic fund transfer patterns in connection with a deposit account.
(3) 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).
(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) The Commission is notified that the customer is not receiving paper account statements.
(6) The Commission is notified of unauthorized charges or transactions in connection with a customer’s covered account.
(e) 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 Commission. A WSSC customer, a victim of identity theft, a law enforcement authority, or any other person who can demonstrate reliability or trustworthiness notifies the Commission that the Commission opened a fraudulent account pursuant to a request by a person engaging in identity theft. (GMO 09-01 § III)