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10-14-08
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10-14-08
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I. PROGRAM ADOPTION <br /> The New Ulm Public Utilities Commission ("NUPUC" or"Utility")developed this <br /> Identity Theft Prevention Program("Program")pursuant to the Federal Trade Commission's Red <br /> Flags Rule ("Rule"),which implements Section 114 of the Fair and Accurate Credit Transactions <br /> Act of 2003. 16 C. F. R. § 681.2. This Program was developed with oversight and approval of <br /> the Program Administrator(defined in VII. A.) and the New Ulm Public Utilities Commission. <br /> After consideration of the size and complexity of the Utility's operations and account systems, <br /> and the nature and scope of the Utility's activities, the Program Administrator determined that <br /> this Program was appropriate for the Utility, and; the program was subsequently approved by the <br /> NUPUC on September 23, 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 NUPUC'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 /> 2 <br />
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