Red Flags Policy
“Red Flags” observed on an Application for credit are a potential indication of fraud. Companies 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.
1. Identifying Relevant Red Flags
Red Flags Defined by the Broker as being Relevant to the Property Management Industry:
- An Active Duty alert on a credit report.
- An Initial Fraud alert on a credit report.
- An Extended Fraud alert on a credit report.
- A Social Security Number that is assigned to a deceased person.
- Pay Stubs appear to have been fabricated or altered.
- Bank Statements appear to have been fabricated or altered.
- The credit file depth is inconsistent with the Applicant’s profile.
- Recently created credit file.
- Brief address history.
- Inconsistencies in the information a customer has submitted.
- Authorized User accounts that are not associated with a spouse.
- Use of secured credit lines to build credit.
- Driver’s License Number not found in the issuing state DMV records.
- Inconsistencies observed on Government issued I.D.s, passports, documents, etc.
- The person presenting the identification doesn’t look like the photo or match the physical description.
- 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:
- Send a request to the Applicant requesting clarification or additional information.
- Issue an FTC Red Flags Notice.
- Notify Law Enforcement.
4. Update the Program
The Broker is a member of the National Association of Residential Property Managers (NARPM) and the Better Business Bureau (BBB), both of 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.