Red Flags Rule: Identity Theft Prevention for Managers Training Course

Hello and welcome to the management-level course that puts you in the pilot's seat of your organization’s compliance efforts. Under the Federal Trade Commission’s (FTC) Red Flags Rule, compliance is not just about frontline employees spotting a suspicious ID; it’s a matter of Governance, Risk Assessment, and Oversight. If your team misses a Red Flag, that's a mistake. If your formal Identity Theft Prevention Program fails to address a known risk, that's a violation—and violations can result in significant penalties.

This session will provide you with the comprehensive, strategic understanding needed to move beyond basic detection and effectively administer a robust program. The Rule requires "Financial Institutions" and "Creditors" to implement a written Identity Theft Prevention Program. We will clarify the FTC's broad definition of a "Creditor," which often includes entities that bill customers later for services—such as healthcare providers and utility companies—meaning your organization may be covered even if you are not a traditional bank.

You must know and actively implement the four essential elements of the Program: Identify the specific Red Flags for your organization; Detect those Red Flags with established procedures; Respond appropriately to prevent and mitigate identity theft; and Update the Program periodically to reflect the constantly evolving threat landscape and technology changes (like new patient portals or mobile apps).

A critical management responsibility we will detail is conducting a periodic Risk Assessment. You'll learn to analyze the three core factors the Rule requires you to consider: the types of covered accounts you offer (accounts for personal, family, or household purposes that involve multiple payments, or any account with a reasonably foreseeable risk of identity theft); the methods you provide to open and access those accounts (online, phone, in-person); and your organization’s previous experience with identity theft. The training will walk you through a scenario demonstrating how a new account access point (like a patient portal) invalidates old detection rules and requires a formal policy update.

Furthermore, you are responsible for rigorous Training and Oversight. This includes ensuring that staff training is customized to the role—call center staff need different training than sales floor staff—and, crucially, that all training is thoroughly documented and records are retained, as "I think we covered that in a meeting" is insufficient for auditors. We also address the liability inherent in Service Provider Oversight. If a vendor (like a collection agency) interacts with covered accounts, you must ensure they follow your Program or have an approved one of their own, as outsourcing the function does not outsource the risk. Finally, we cover the requirement to provide a formal annual report on the Program's effectiveness to the Board of Directors, ensuring senior management is informed and driving the necessary resource allocation and policy updates.

This training is essential for any designated Program Administrator, Department Manager, Compliance Officer, or Senior Management employee at a "financial institution" or "creditor" with covered accounts who is tasked with administering, overseeing, or approving the organization's Identity Theft Prevention Program.

This program is available with Spanish and French closed captions.