In order to identify relevant red flags, the City of El Paso
considers the types of accounts that it offers and maintains, the
method it provides to open its accounts, the methods it provides to
access its accounts, and its previous experiences with identity theft.
The City of El Paso identifies the following red flags concerning
notifications and warnings from credit reporting agencies:
A.
A report of fraud accompanying a credit report;
B.
A notice or report from a credit agency of a credit freeze on a customer
or an applicant;
C.
A notice or report from a credit agency of an active-duty alert for
an applicant; and
D.
Indication from a credit report of activity that is inconsistent
with a customer's usual pattern of activity.
The City of El Paso identifies the following red flags concerning
suspicious documents:
A.
Any identification document or card that appears to be forged, altered
or inauthentic;
B.
Any identification document or card on which a person's photograph
or physical description is not consistent with the person presenting
the document;
C.
Any other document with information that is not consistent with existing
customer information (such as if a person's signature on a check appears
forged); and
D.
Any application for service that appears to have been altered or
forged.
The City of El Paso identifies the following red flags concerning
suspicious personal identifying information:
A.
Any identifying information that is presented that is inconsistent
with other information that the customer provides (such as inconsistent
birth dates);
B.
Any identifying information that is presented that is inconsistent
with other sources of information (such as an address that does not
match the address on a credit report);
C.
Any identifying information that is presented that is the same as
information shown on other applications that were found to be fraudulent;
D.
Any identifying information that is presented that is consistent
with fraudulent activity (such as invalid phone number or fictitious
billing address);
E.
A social security number that is presented that is the same as one
given by another customer;
F.
An address or phone number that is presented that is the same as
that of another person;
G.
Any instance where a person fails to provide complete personal identifying
information on an application after being reminded to do so; and
H.
Any instance where a person's identifying information is not consistent
with the information that is on file for that customer.
The City of El Paso identifies the following red flags concerning
suspicious account activity or an unusual use of an account:
A.
A change of address for an account that is followed by a request
to change the account holder's name;
B.
Any instance where payments stop on an otherwise consistently up-to-date
account;
C.
Any instance where an account is used in a way that is inconsistent
with its prior use (example: very high activity);
D.
Any instance where mail that was sent to the account holder is repeatedly
returned as undeliverable;
E.
Any instance where the City of El Paso is notified that a customer
is not receiving mail that was sent by the City of El Paso;
F.
Any notice to the City of El Paso that an account has unauthorized
activity;
G.
A breach of the City of El Paso's computer-system security; and
H.
Any unauthorized access to or use of customer account information.
The City of El Paso identifies it as a red flag if the City
of El Paso receives notice from a customer, an identity theft victim,
law enforcement, or other person that the City of El Paso has opened
or is maintaining a fraudulent account for a person engaged in identity
theft.
