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Federal Trade Commission (FTC) Identity Theft Prevention Program (ITPP) Red Flags Policy

“Red Flags” observed on an Application for credit are a potential indication of fraud. Companies, like Real Estate Brokerages, that are involved in a decision to extend credit are required by the Federal Trade Commission to publish a policy defining Red Flags and take the reasonable actions required to stop fraud. The ITPP is designed to help identify, detect, and respond to red flags, or warning signs, of identity theft. In the process of reviewing an Application or Credit Report if issues are discovered that could be resolved or clarified by requesting additional information, then the Broker will promptly send an email to the Applicant describing the concern and requesting that the Applicant immediately respond to the Broker to either: (1) reply with an email challenging the Broker’s concern or (2) reply with an email providing a reasonable explanation or (3) reply with an email supplying additional documentation sufficient to address the Broker’s concern. If the Broker does not receive an email from the Applicant within 3 business days, then the Broker will issue a Notice of an Incomplete Application. When, in the sole opinion of the Broker, the Red Flags are obvious and blatant, the Broker reserves the right to initially respond with a FTC Red Flags Notice.

1. Identifying Relevant Red Flags

Red Flags Defined by the Broker as being Relevant to the Property Management Industry:

  1. An Active Duty alert on a credit report.
  2. An Initial Fraud alert on a credit report.
  3. An Extended Fraud alert on a credit report.
  4. A Social Security Number that is assigned to a deceased person.
  5. Pay Stubs appear to have been fabricated or altered.
  6. Pay Stubs were reported as fraudulent or possibly fraudulent by Fraud Detection Software.
  7. Bank Statements appear to have been fabricated or altered.
  8. Bank Statements were reported as fraudulent or possibly fraudulent by Fraud Detection Software.
  9. The length of credit history is inconsistent with the Applicant’s age.
  10. Recently created credit file.
  11. Brief address history.
  12. Inconsistencies in the information a customer has submitted.
  13. Authorized User accounts that are not associated with a spouse.
  14. Driver’s License Number not found in the issuing state DMV records.
  15. Inconsistencies observed on Government issued I.D.s, passports, documents, etc.
  16. The person presenting the identification doesn’t look like the photo or match the physical description.
  17. Identification looks altered or forged.

2. Detecting Red Flags

The Broker collects personal information from the Rental Customer through a Lease Application and compares the information in the Credit Bureau Report and a Background Report purchased from the Broker’s report vendor.

3. Prevent and Mitigate Identity Theft

Depending on the number of Red Flags detected and their severity, the Broker will:

  1. Send a request to the Applicant requesting clarification or additional information.
  2. Issue an FTC Red Flags Notice.
  3. Notify Law Enforcement.

4. Update the Program

The Broker is a member of the Better Business Bureau (BBB) which continually send the Broker information on this topic.

The Broker uses the most up to date technology and methods for collecting and transmitting personal information collected from Clients and Customers, including encryption and other security methods.