We have a few things rolling around in our programming department, but to begin, let’s discuss the basics of what your new identity theft program must accomplish.
The regulation states that a financial institution program must be designed to detect, prevent, and mitigate identity theft in connection with the opening of a covered account or any existing covered account. It further describes methods which a credit union can use to accomplish those tasks and how you must augment your existing CIP program to meet the intent of the regulation.
There are four main pieces of the regulation, many of which are internal to the credit union’s practices. However, there is at least one section that addresses authentication of member information. That is where CU*Answers has begun investing programming time to help you meet the requirements of this complex new law.
The Advisor Suggests…
This advice is designed to address the opening of a covered account and how you perform your diligence on the information supplied to you.
This summer CU*Answers began investigating services provided by existing credit bureaus to build a tool to authenticate the data a new member supplies to the credit union at account opening.
Leveraging our interface with ZOOT and the existing tools and features of the CU*BASE platform was a major goal of our search. We decided on programming an interface to Experian’s Authentication Services Level One (AS1) as the tool to help you meet the requirements of your new procedure and policies.
According to the Act, a financial institution must authenticate the potential new member through the verification of the member’s address, Social Security number, and other personal identification information such as a driver’s license.
Experian uses multiple data sources in this verification process, including their own header data in the credit file, Social Security Administration data, deliverable address data, and many other proprietary data sources.
In our due diligence we believe we have obtained the best solution and Experian allowed us to bring our entire client base to the table at once, which gave us a great price on the process.
How will it work?
Credit unions will be allowed to enter the actual pull of the AS1 into the account opening workflow process. The process will be similar to the OFAC scan with a few cool twists.
In the event a data element fails the specific test the system will allow the user to actually go in an update the data if was incorrect and resubmit the request, up to a total of 3 tries.
Once the employee is satisfied with the data, the results of the final pull will be recorded and an Audit Tracker record will be written out the new members account for a permanent record in CU*BASE.
We will also be creating a new file which you will be able to inquire upon that includes all the results, verifications, and validations which Experian returns, including:
- Address verification
- Address type
- Address if in a high risk area
- Phone verification
- Phone if in a high risk area Social Security verification
- Social Security validation
- Date of birth verification
- Driver’s license validation
- Driver’s license verification
- OFAC verification
This new product will make the verification process easy and will effectively make the new requirements effortless. So if you were having problems determining how you were going to meet the requirements imposed by the regulation for the account opening process, take a hard look at the new AS1 solution.
If your credit union wants to get started now, you would be enrolled with Experian and set up to access the tool via a website. A number of our clients already use the tool this way.
Coming in early 2009, this feature will be fully integrated into CU*BASE as part of new member account opening!
To help you decide, coming soon, Lender*VP will be co-sponsoring enrollment web conferences with the Experian AS1 team to introduce the product and cover the enrollment details. We’ll be holding two separate web conferences: one for new clients just wanting to get started, and another, separate event for clients already using the AS1 web tool and wanting to see about what’s needed to roll over to the CU*BASE integrated product next year. Watch your email for more details coming soon!
For more information about this product, please contact Beth Skinner at firstname.lastname@example.org.