information beyond that which generally would be available from a wallet or consumer report.
b.4: Unusual use of, or suspicious activity related to, a covered account
(a) Shortly following the notice of a change of address for a covered account, the college receives a request for new, additional, or replacement goods or services, or for the addition of authorized users on the account.
(b) A covered account is used in a manner that is not consistent with established patterns of activity on the account. There is, for example:
• Nonpayment when there is no history of late or missed payments; • A material change in purchasing or usage patterns.
(c) 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).
(d) Mail sent to the customer is returned repeatedly as undeliverable although transactions continue to be conducted in connection with the customer’s covered account.
(e) The college is notified that the customer is not receiving paper account statements.
(f) The college is notified of unauthorized charges or transactions in connection with a student’s covered account.
(g) The college receives notice from students, victims of identity theft, law enforcement authorities, or other persons regarding possible identity theft in connection with covered accounts held by the college
(h) The college is notified by a customer, a victim of identity theft, a law enforcement authority, or any other person that it has opened a fraudulent account for a person engaged in identity theft.
c: Detection of Red Flags
The Program’s general Red Fag detection practices are described in this document. Each department will develop and implement specific methods and protocols appropriate to meet the requirements of this Program.
c.1: New Accounts
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