Pub. 3 2018 Issue 6
17 ISSUE 6 2018 Suspicious Documents: 1. Identification document or card that appears to be forged or altered; 2. ID or card on which a person’s photograph or physical description is not consistent with the person presenting the document; 3. Other documentation not consistent with customer information (such as a person’s signature on a check appearing forged); 4. Application for residency that ap- pears to have been altered or forged. Suspicious Personal Identifying Information: 1. Identifying information present- ed that is inconsistent with other information the customer provides (such as inconsistent birth dates); 2. Identifying information present- ed that is inconsistent with other sources of information (ex. an address not matching an address on a credit report); 3. Identifying information presented that is the same as information shown on other applications that were found to be fraudulent; 4. Identifying information presented that is consistent with fraudulent activity (such as an invalid phone number or fictitious billing ad- dress); 5. Social security number presented that is the same as one given by another customer; 6. An address or phone number presented that is the same as that of another person; 7. A person fails to provide complete personal identifying information on an application when reminded to do so (however, by law SS #’s must not be required); 8. A person’s identifying information is inconsistent with the information that is on file for the customer. Suspicious Account Activity or Unusual Use of Account: 1. Change of address for an account followed by a request to change the resident’s name; 2. Stop Payment on an otherwise con- sistently up-to-date account; 3. Mail sent to the Resident is repeat- edly returned as undeliverable; 4. Notice to the Landlord that a Res- ident is not receiving mail sent by the landlord; 5. Breach in the Landlord’s computer system security – unauthorized ac- cess to or use of Resident’s account information; 6. Attempt to pay full year’s rent in advance; 7. Rent payments begin being made by a third party. Detecting Red Flags: In order to detect any of the Red Flags identified above associated with an application for residency, it is recom- mended staff take the following steps to obtain and verify the identity of the person submitting the application: 1. Require certain identifying infor- mation such as name, date of birth, address, driver’s license or other identification; 2. Verify the applicant’s identity (for instance, review a driver’s license or other ID card); 3. Independently contact the applicant to verify all information provided in the application for residency against information disclosed in the consumer report including prior addresses, complete applicant name and identifying numbers. In order to detect any of the Red Flags identified above for a current Resident, The program administrator, a designated staff member or member of upper management, should periodically review and update the company policy to reflect changes in risks to residents and applicants from Identity Theft.
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