In order to detect any of the Red Flags identified above associated with the opening of a new account, College personnel will take appropriate steps to obtain and verify the identity of the person opening the account. Such steps may include the following: (a) Require certain identifying information such as name, date of birth, residential or business address, driver's license or other identification; (b)Verify the customer's identity (for instance, review a driver's license or other identification card);
(c) Independently contact the customer.
c.2: Existing Accounts In order to detect any of the Red Flags identified above for an existing account, College personnel will take appropriate steps to monitor transactions with an account. Such steps may include the following: (a)Verify the identification of customers if they request information (in person, via telephone, via facsimile, via email);
(b) Verify the validity of requests to change billing addresses; and (c) Verify changes in banking information given for billing and payment purposes.
RESPONDING TO RED FLAGS
a: Once potentially fraudulent activity is detected, the college will act promptly to protect students and the college from damages and loss.
a.1: The college will gather all related documentation and write a description of the situation, then present this information to the Vice President for Finance and Administration, or his/her designee for determination.
a.2: The Vice President for Finance and Administration, or his/her designee will complete additional authentication to determine whether the attempted transaction was fraudulent or authentic.
b: If a transaction is determined to be fraudulent, appropriate actions must be taken immediately. Actions may include:
1. Canceling the transaction or the account; 2. Notifying and cooperating with appropriate law enforcement; 3. Determining the extent of liability of the college; and 4. Notifying the actual student that fraud has been discovered.
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