Identity Theft Policy

Red Flags Policy

Identity Theft Prevention Program (ITPP)

1. Program Purpose and Scope

Dean & Associates Inc. (“Broker”) has developed this Identity Theft Prevention Program (“Program”) in accordance with the Federal Trade Commission’s Red Flags Rule (16 CFR § 681.2). The purpose of this Program is to detect, prevent, and mitigate identity theft in connection with residential lease applications and ongoing lease obligations.

This Program applies to all lease applications, Tenant screening activities, and accounts involving ongoing payment obligations.

2. Covered Accounts

The Broker maintains “Covered Accounts” as defined under 16 CFR § 681.2, including residential lease accounts that involve ongoing payment obligations and present a reasonably foreseeable risk of identity theft.

3. Definitions

Applicant: Any individual submitting a lease application.
Tenant: Any individual approved for and entering into a lease agreement.
Red Flag: A pattern, practice, or specific activity that indicates the possible existence of identity theft.

4. Program Administration

This Program is administered by the Broker or a designated responsible employee (“Program Administrator”). The Program Administrator is responsible for implementation, oversight, enforcement, and periodic review of this Program.

5. Identifying Relevant Red Flags

The Broker has identified the following Red Flags as being relevant to the property management and leasing 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 assigned to a deceased person.
  5. Pay stubs that appear fabricated or altered.
  6. Pay stubs reported as fraudulent or potentially fraudulent by fraud detection software.
  7. Bank statements that appear fabricated or altered.
  8. Bank statements reported as fraudulent or potentially fraudulent by fraud detection software.
  9. The length of credit history is inconsistent with the Applicant’s age.
  10. Recently created or insufficient credit history inconsistent with stated background.
  11. Inconsistent or unverifiable address history.
  12. Inconsistencies in information provided by the Applicant.
  13. Authorized user accounts inconsistent with a spouse or household member.
  14. Driver’s License Number not found or not matching issuing state records.
  15. Inconsistencies observed in government-issued identification documents.
  16. The individual presenting identification does not reasonably match the photo or physical description.
  17. Identification that appears altered, forged, or otherwise unreliable.

6. Detecting Red Flags

The Broker detects Red Flags through a combination of the following methods:

  • Review of lease applications and supporting documentation
  • Consumer credit reports obtained from national credit reporting agencies
  • Background and eviction reports obtained from third-party vendors
  • Identity verification tools and fraud detection software, including but not limited to Snappt
  • Review of bank account data and/or bank statements where applicable
  • Comparison of Applicant-provided information with third-party data sources
  • Review of government-issued identification documents

The Broker does not rely solely on any single source of information but evaluates all available data collectively.

7. Responding to Red Flags

Upon detection of one or more Red Flags, the Broker will take appropriate action based on the nature, severity, and reliability of the information.

Such actions may include, but are not limited to:

  1. Requesting additional information or documentation from the Applicant
  2. Requiring enhanced identity verification through third-party services
  3. Suspending processing of the application pending clarification
  4. Declining the application where identity cannot be reasonably verified
  5. Refusing to accept documentation determined to be unreliable or unverifiable
  6. Issuing a notice of incomplete application
  7. Reporting suspected fraud to appropriate law enforcement authorities when warranted

All determinations will be made based on the Broker’s reasonable assessment of the available information.

8. Service Provider Oversight

The Broker utilizes third-party service providers for identity verification, credit reporting, background screening, and fraud detection.

The Broker will take reasonable steps to ensure that such service providers maintain appropriate policies and procedures designed to detect, prevent, and mitigate identity theft.

9. Employee Training

Employees involved in leasing, application processing, and account management will receive training appropriate to their responsibilities to enable them to identify, detect, and respond to Red Flags.

10. Program Updates

The Broker will periodically review and update this Program to reflect:

  • Changes in identity theft risks
  • Changes in methods used to detect, prevent, and mitigate identity theft
  • Changes in business practices, including the use of new technologies or service providers
  • The effectiveness of the Program in addressing identity theft risks

11. Recordkeeping

The Broker will maintain internal records of detected Red Flags and actions taken in response, consistent with applicable record retention policies and legal requirements.

12. Customer Communication

If issues are identified that require clarification, the Broker may contact the Applicant and request a prompt response. Failure to provide sufficient information within a reasonable timeframe may result in the application being deemed incomplete.

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