Identity Theft Prevention Program Checklist

Review these questions to ensure your credit union’s identity theft program is effective.

9/12/17

League InfoSight has provided a checklist of questions to help credit unions ensure they have an effective identity theft program in place. All answers to the following questions should be “yes,” unless they are not applicable to your credit union.

  1. Has your credit union established an Identity Theft Prevention Program, as required by the Fair and Accurate Credit Transactions Act (FACT Act)?
  2. Is the program written and approved by the Credit Union Board of Directors or an appropriate committee of the Board?
  3. Does the program identify potential identity theft red flags for the covered accounts?
  4. Does the program provide for the detection of such red flags?
  5. Does the program provide for the appropriate response to identity theft red flags that are identified in connection with accounts and transactions?
  6. Is the program updated periodically, as necessary, to reflect changes in risks to members?
  7. Is either the Board, an appropriate committee of the Board, or a designated senior level management employee of the credit union involved in the development, implementation, and continued oversight of the program?
  8. Is staff trained, as necessary, to effectively implement the Identity Theft Prevention Program?
  9. Does the credit union exercise effective oversight of service provider arrangements?