FACT Act Identity Theft Prevention Program Mandates

Question: What are the FACT Act Identity Theft Prevention Program mandates regarding changes of address for financial institutions that issue debit and credit cards?

Answer: The FACT Act mandates that financial institutions establish and implement reasonable policies and procedures to assess the validity of a consumer cardholder's new address when a change of address is received and there is a request for an additional or replacement card for the account shortly thereafter. A card issuer may not issue an additional or replacement card until the cardholder's new address is validated in accordance with these policies and procedures. Validation must include notifying the cardholder of the request at his or her former address or by whatever means to which the parties have previously agreed. Any written or electronic notice to the cardholder must be clear, conspicuous and separate from other regular correspondence. This rule does not preclude nonwritten validation methods. The issuer must provide a reasonable means by which the cardholder can report incorrect address changes or through which the validity of the address change is otherwise confirmed. Operationally, a card issuer need not wait for a replacement card request. The issuer can validate the new address before it receives a request for an additional or replacement card. For more information on how your institution should respond to the Red Flags Rule requirements, click here
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First published on BankersOnline.com 10/27/08