Fair Credit Reporting: 9.2.7.2.3 Requirements
Under the regulations, each creditor must “include reasonable policies and procedures” for issuing and implementing “Red Flag” guidelines regarding identity theft.296 A “Red Flag” is “a pattern, practice, or specific activity that indicates the possible existence of identity theft.”297 Financial institutions and creditors that maintain accounts described in the regulations must “develop and implement a written Identity Theft Prevention Program . . .