Identity Verification and FACT Act Red Flag Compliance for Educational Institutions

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Automated Online Red Flag Rules Compliance for Educational Institutions

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Red Flag Rules for Universities, Colleges and Schools

	Universities
	Colleges
	Private Schools

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Colleges and universities that accept deferred payments on accounts or extend credit for non-business purposes fall within the definition of “creditor,” requiring compliance with these rules.

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As a College, University or Private Educational Organization, you may be considered a “creditor” as defined by the Federal Trade Commission and may be required to comply with Red Flags Rule. If you collect, store or share non-public information from students or the parents of the students (and/or employees) such as Social Security numbers, and/or banking information… or if you have students or the parents of the students complete a credit application and/or forms containing non-public information... or your 3rd party service providers run credit and/or background checks and handle debt collection for your Educational organization, you MUST comply with this Federal Law or be subject to significant fines and penalties!

Testimonials

Veratad's Red Flag Document Generator and Employee Training tools made it so easy for us to get started with our Red Flag Rules compliance; in fact, I don’t believe we could have accomplished what we did without them. It was all we needed and more…” “…working through Veratad’s step-by-step compliance portal forced us into a very good process that led us to a very valuable review of how we do things in different departments.”

Elisabeth Dahlen
Assistant to the Treasurer for Special Projects
Princeton University

“Having now completed our Red Flag Program, I would estimate that Veratad’s Red Flag Document Generator reduced the amount of time
necessary to construct our Identity Theft Program by 95%.”

“Determining how to handle the different complexities of covered accounts in various departments was our biggest challenge. The flexibility of the Veratad Document Generator allowed us to separate the covered accounts by department allowing each to create an individualized risk assessment for their department.”

Wanda Mizutowicz
Associate Vice President for Finance and Controller
University of Texas at Dallas

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Other activities that could cause colleges and universities to be considered "creditors" subject to the Red Flag Rules include:

participating in the Federal Perkins Loan program;
participating as a school lender in the Federal Family Education Loan Program:
offering institutional loans to students, faculty or staff; and
offering payment plans for tuition that extend payments throughout an academic period rather than requiring payment at the beginning of the academic period.

FINES FOR NON-COMPLIANCE

Federal Trade Commission - The FTC is also authorized to bring enforcement actions in federal court for violations. In some cases, the FTC may bring an action for up to $2,500 in penalties for each independent violation of the rule.

State Enforcement - The states are also authorized to bring actions on behalf of their residents and may recover up to $1,000 for each violation. In addition, the states may recover its attorneys’ fees if successful in such action.

Civil Liability - Each consumer may be entitled to recover actual damages sustained from a violation. This could be very large and consumers may be able to bring a class action suit seeking potentially massive damages. In addition, successful plaintiffs may recover reasonable attorneys’ fees.

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Key “Red Flags” Rule Requirements:

Designate a Compliance Officer / Program Coordinator
Perform a Risk Assessment to determine “Red Flags”
Develop a “written” Identity Theft Prevention Program (ITPP)
Ensure program contains your Policies and Procedures
Documented proof vendors you share sensitive information with are compliant by having proper protection and safeguards in place
Develop an employee training program & train all employees who handle sensitive information to know how to identity, detect and respond to Red Flags…and if an event occurs, you must have a policy in place to notify affected students or the parents of the students according to policy
Perform periodic audits
Obtain Board or Top Executive Approval
Annual Reports to record compliance

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Service includes an online tool that helps you create your Identity Theft Prevention Program Document and facilitates online Identity Theft Red Flags Employee Training customized with your red flags. In addition, Veratad provides an easily deployable Identity Verification Solution with "out of wallet" questions and optional OFAC Search.

Online Program Document Creation

Our service follows the FACTA guidelines and prompts you as you create a complete Identity Theft Prevention Program document. Subscribers to our service can simply log-in, complete a series of questions and download a customized Program document in Microsoft Word or Adobe Acrobat format.

Online Employee Training

In addition, your organization will receive access to an online Identity Theft Red Flags Employee Training Module completely under your direction.

Online Identity Verification

Veratad’s flagship products IDMatch and IDMatch+PLUS are ideal for meeting the identity and change of address "red flag" requirements of Section 114 and 315 of FACTA because they provide an easily deployable Identity Verification Solution with different levels of authenticating identities. In addition to ID Verification, Veratad can include OFAC.

Veratad's Red Flag Rules Compliance Solutions

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Red Flag Rules Document/Training Video

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