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SI. PROGRAM ADOPTION <br /> The [Utility Name] ("Utility")developed this Identity Theft Prevention Program <br /> ("Program")pursuant to the Federal Trade Commission's Red Flags Rule("Rule"), which <br /> implements Section 114 of the Fair and Accurate Credit Transactions Act of 2003. 16 C. F. R. § <br /> 681.2. This Program was developed with oversight and approval of the [Program Administrator <br /> (defined below) OR Utility Commission OR City Council]. After consideration of the <br /> size and complexity of the Utility's operations and account systems, and the nature and scope of <br /> the Utility's activities, the [Program Administrator OR Utility Commission OR City <br /> Council] determined that this Program was appropriate for the [Utility Name], and therefore <br /> approved this Program on , 2008. <br /> II. PROGRAM PURPOSE AND DEFINITIONS <br /> A. Fulfilling requirements of the Red Flags Rule <br /> Under the Red Flag Rule, every financial institution and creditor is required to establish an <br /> "Identity Theft Prevention Program"tailored to its size, complexity and the nature of its <br /> operation. Each program must contain reasonable policies and procedures to: <br /> 1. Identify relevant Red Flags for new and existing covered accounts and incorporate those <br /> Red Flags into the Program; <br /> 2. Detect Red Flags that have been incorporated into the Program; <br /> 3. Respond appropriately to any Red Flags that are detected to prevent and mitigate Identity <br /> Theft; and <br /> 4. Ensure the Program is updated periodically, to reflect changes in risks to customers or to <br /> the safety and soundness of the creditor from Identity Theft. <br /> B. Red Flags Rule definitions used in this Program <br /> The Red Flags Rule defines "Identity Theft"as "fraud committed using the identifying <br /> information of another person"and a"Red Flag" as "a pattern, practice, or specific activity that <br /> indicates the possible existence of Identity Theft." <br /> According to the Rule, a municipal utility is a creditor subject to the Rule requirements. The <br /> Rule defines creditors "to include finance companies, automobile dealers, mortgage brokers, <br /> utility companies, and telecommunications companies. Where non-profit and government <br /> entities defer payment for goods or services, they,too, are to be considered creditors." <br /> All the Utility's accounts that are individual utility service accounts held by customers of the <br /> utility whether residential, commercial or industrial are covered by the Rule. Under the Rule, a <br /> "covered account" is: <br /> • <br /> 2 <br />