Friday, August 28, 2009

Red Flag Compliance Rules for Mortgage Brokers

Red Flags FTC enforcement has been set for November 1, 2009
but Red Flag Compliance for Mortgage Brokers and others who
qualify are in effect NOW under the Red Flag Rules.

Mortgage Brokers and Lenders come under the "Creditor"
and "Covered Accounts" categories.


"FACTA’s definition of “creditor” applies to any entity that regularly extends or renews credit – or arranges for others to do so – and includes all entities that regularly permit deferred payments for goods or services."

"Some examples of creditors are finance companies; automobile dealers that provide or arrange financing; mortgage brokers..."
Federal Trade Commission Website


IF YOU THINK THIS IS A "MINOR" ISSUE...GUESS AGAIN

Mortgage Lender Will Pay $50,000 Civil Penalty for Violating FCRA Disposal Rule (December 18, 2007)

Mortgage Servicers Agree to Pay $28 Million to Settle FTC Charges, Including Failure to Report Consumer Disputes to Credit Bureaus as Required by the FCRA (September 9, 2008)

FTC Charges Mortgage Broker With Violations of FCRA and Disposal Rule, Seeks Monetary Civil Penalties (December 30, 2008)

Mortgage Lender Pays $20,000 to Settle FTC Charges That Its Prescreened Loan Offers Lacked Proper Opt-Out Notice (08/18/2009)

PERHAPS THESE STORIES WILL CONVINCE YOU...
THE FTC IS WATCHING AND THEY ARE HANDING OUT FINES

Failure of Mortgage Brokers to Comply with Red Flag Rules
can leave the Broker open to Civil Litigation which may extend
to Class Action...and the Broker will Still Have to Become Compliant
(and, perhaps be subjected to Monthly Audit of continued Compliance).


HOW CAN I BECOME RED FLAGS COMPLIANT?

You should go to this Website and see about the Services

You are Invited to Attend one of the Red Flags Webinars
The Webinars are for Referral Partners of the Service
however, it is an open Q&A and you may attend...
Bring Your Questions...

To Register for the Webinar Tuesday September 1, 2009
Tue, Sep 1, 2009 8:30 PM - 9:30 PM EDT

GET STARTED NOW

Contact Us: GetCompliant@gmail.com

Tuesday, August 25, 2009

Red Flag Rules for Red Flag Compliance

The FTC is the government agency that will be enforcing the
Red Flag Rules for Red Flag Compliance of Consumer laws for
protection from Identity Theft.

Any Company that works with Consumer Credit
is now required to have in place an
Identity Theft Prevention program by November 1st, 2009.

Three Things You Must Ask BEFORE Starting
The Red Flags Compliance Process.

1. Is my company required to meet the Red Flags Compliance Rules?
2. What if my company is not in compliance by November 1, 2009?
3. What is the Fastest and Easiest way to become compliant?



he Red Flags Rules are a part of section 114 of the
Fair and Accurate Credit Transactions (FACT) Act of 2003.

Start now it takes time to become compliant

Businesses who must comply

Businesses that must comply are:

  • banks

  • credit unions

  • mortgage brokers

  • auto dealers

  • debt collection agencies

  • credit issuers

  • utility companies

  • telecommunication companies

  • health care companies

  • ... in short, any company using any consumer's credit report.

Come to Our Webinar Tuesday August 25th to Learn More

Tue, Aug 25, 2009 8:30 PM - 9:30 PM EDT


Contact Us: GetCompliant@gmail.com

Thursday, August 20, 2009

FTC Red Flag Rules

The FTC did not do much to give Businesses a good explanation
of the Red Flag Rules for the last enforcement date of August 1,
so a postponement of FTC enforcement set a new deadline, which
is currently November 1, 2009.

Many businesses and business owners felt uninformed and were
confused about not just whether they actually had to comply
with this "Red Flag thing" but also "what the heck does the FTC
have to do with this and why do they care?"

Well, partly because it is a little know fact that
The primary oversight of the credit reporting agencies/Bureaus,
mortgage brokers and others as to their activities covered by
the Fair Credit Reporting Act (FCRA) is covered by the
Federal Trade Commission (FTC) just as the Lenders, Banks and
Credit Unions (Financial Institutions) are regulated by the FDIC.

All FDIC oversight of large Financial Institutions was required
to be completed in 2008. However, many smaller shops, such
as Hard Money Lenders, Mortgage Brokers, and Credit Unions
have failed to move to Compliance at this time.

The Federal Reserve has oversight on federally-chartered banks
but it is the FTC that Mainstream America will be dealing with
as the Federal Government moves to place more responsibility
for Consumer Identity Theft protections at points of contact.



IMPORTANT CRITERIA UNDER FTC RED FLAG RULES

  • Do they Take a Credit Application or Pull a Credit Report?
  • Then they have to be Red Flags Compliant

EVERY Mortgage Broker, Regardless of Size of the Office
Must be Red Flags Compliant

Landlords and Real Estate Management Companies
Must be Red Flags Compliant
(a Landlord or Property Management Company would not
necessarily have to be Compliant for current Tenants known
to them, but would be required to be Compliant for any new
vacancies involving new applications to rent and pulling any
Consumer Credit Reports

Visit this Blog for continued Red Flag Rules News
Bookmark This Page

What you Must Do Now

Go to This Website
To receive your Complimentary Red Flag Guide
Just enter your information and it will be emailed to you
(There is No Cost, No Obligation and they do not put you on any
type of list....No Marketing and they Never Sell Any Names)

The Business is mainly based on Referral Customers and
the Red Flags Compliance Program here not only gets you fully
documented and Compliant but also includes a Full 12 months
of Maintenance and Follow-up Access.

Contact Us: getcompliant@gmail.com

Tuesday, August 18, 2009

Red Flags Identity Theft Prevention Program

According to a report of the President’s Identity Theft Task Force, identity theft (a fraud attempted or committed using identifying information of another person without authority), results in billions of dollars in losses each year to individuals and businesses.

The final rules require each financial institution and creditor that holds any consumer account, or other account for which there is a reasonably foreseeable risk of identity theft, to develop and implement an Identity Theft Prevention Program (Program) for combating identity theft in connection with new and existing accounts. The Program must include reasonable policies and procedures for detecting, preventing, and mitigating identity theft and enable a financial institution or creditor to:

  1. Identify relevant patterns, practices, and specific forms of activity that are “red flags” signaling possible identity theft and incorporate those red flags into the Program;
  2. Detect red flags that have been incorporated into the Program;
  3. Respond appropriately to any red flags that are detected to prevent and mitigate identity theft; and
  4. Ensure the Program is updated periodically to reflect changes in risks from identity theft.

Red Flags is a Follow up to Data Protection

"Identity Theft is fully out of control," said National Red Flags
Compliance expert Lee Holden.

"in 1999 there were approximately 1 million victims of identity
theft. Currently there are about 14 to 15 million victims each
year," said Holden.

"Twenty five people every minute of every day, 24/7. When
I do a one hour Webinar on Red Flags Compliance, in just that
one hour, 1500 people will have been effected by some form of
identity theft."

And, who needs to be compliant, Holden was asked.

"Anyone who originates a loan, even a Doctor's Office," said Holden.

"Why even a Doctor's Office? There are at least three reasons,"
Holden said.

"One, they send bills after the patients have left the office.
Also, the individual is ultimately the one responsible for the
payment (so, in essence, the office has extended credit) and
a third reason is the Doctor may bill and collect co-payments,
after any insurance makes their payments.

Identity Theft Prevention Program

To find out more about Red Flags Compliant Rules or to
request a complimentary consultation with Lee Holden, go to:
RedFlagsCompliant.com

SIGN UP NOW FOR OUR NEXT Q&A WEBINAR
WITH NATIONAL RED FLAGS EXPERT LEE HOLDEN
Tue, Aug 25, 2009 8:30 PM - 9:30 PM EDT

Contact Us: getcompliant@gmail.com

Tuesday, August 11, 2009

Who, What, Where, When and Why of Red Flags Webinar

Tuesday, August 11, 2009 8:30 PM - 9:30 PM EDT
Red Flags Compliant Webinar with Lee Holden


The Who, What, Where, When and Why of Red Flags

Red Flags Compliant Webinar
with Lee Holden

What is the program all about? What do our customer get?

Bring your questions - and we'll get you answers!

Register for the Webinar:
https://www2.gotomeeting.com/register/583070331

For Additional Information on Lee Holden's Services
click the link to find out how You and Your Business
can get Compliant...RedFlagsCompliant

Contact Us: getcompliant@gmail.com

Monday, August 10, 2009

26 Red Flags Compliance Webinar

There are 26 Federal Government Red Flags identified...

You must have a plan to safeguard identities and a manual of
ongoing Compliance as a business plan of operations.

To give you an opportunity to understand the Red Flags Rules
Fix Credit Biz will host a Tuesday Night Webinar with National
Speaker, Red Flags Expert Lee Holden

Subject: 26 Red Flags In Lending

Here are just a few of the Topics Lee will cover in the Webinar.
It's Open Forum format, so Bring Your Questions and you'll get
an opportunity to Ask Lee Holden your Red Flags Compliance
Question.

• Identity Relevant Red Flags for Your Organization & Implement Required
Detection and Response Procedures

• Have a Written Program – Approved by Board of Directors or Senior Manager or
Owner

• Program Must Be “Effective” – i.e. (What is in written program is what you must be doing)


Get Your No Cost, No Obligation
Red Flags Compliant Jumpstart Guide

To Register and Join Us on the Webinar:
Tues, Aug 11, 2009 8:30 PM - 9:30 PM EDT

To Contact Us: getcompliant@gmail.com

Sunday, August 9, 2009

How Does Red Flags Compliance Work?

There is so little Mainstream News about the FTC mandatory
Red Flags Compliance, I think some wonder "what is this thing
all about," "How does Red Flags Compliance work" and who" the
heck needs to to worried about it anyway?"

Well, the Red Flags Compliance is a real program...it is, in fact,
the Law RIGHT NOW! What has been delayed is the FTC
Enforcement of the Law...but those who need to be Compliant
need to get compliant RIGHT NOW...it IS the law and, current
actions today do indeed count as violations of the Red Flag Rules.

Health-care providers must have “reasonable” policies
and procedures in place...but, how does that work?

Pharmacies must guard against identity theft for Red Flags
Compliance (and must have a policy in place).

Auto Dealerships need Compliance and each dealership that
required, have its own in-store compliance officer.

The Federal Trade Commission/FTC is now providing additional
resources and guidance to clarify whether businesses are covered
by the Red Flags rule and what they must do to comply...but, do
you wait for the FTC to see how it works or are you saying, now
"How does the Red Flags certification work?"

We invite you to our Red Flag Compliance Webinar-
a comprehensive overview of RedFlagsCompliant
with National Red Flags Expert Lee Holden

On the webinar Lee will be addressing the following:

What is the Red Flag Rule?
What is the program all about?
What do our customer get?


Allow us to make you red flags rule compliant!

Q & A open forum Webinar with Expert Lee Holden
Tue, Aug 11, 2009 8:30 PM - 9:30 PM EDT
Bring your questions - and we'll get you answers!

We hope you can Join Us!
If you cannot make the Tues. 8/11 Webinar
please register in advance, now for Tues 8/18


Tue, Aug 18, 2009 8:30 PM - 9:30 PM EDT


Contact Us: GetCompliant@gmail.com

Tuesday, August 4, 2009

Red Flags Compliant Guide

Get your Red Flags Compliant Guide
before Tonight's Webinar with Red Flags Expert Lee Holden
Tue, Aug 4, 2009 8:30 PM - 9:30 PM EDT


Free Red Flags Compliant Jumpstart Guide
to meeting compliance.

While complying with Red Flags is not difficult you need to have a
comprehensive written program, that takes into account your organization,
its processes, types of accounts and a through risk assessment and let us
not forget the training.

• Perform a Risk Assessment & Identify Covered Accounts – How they are opened
and the sales process

• Identity Relevant Red Flags for Your Organization & Implement Required
Detection and Response Procedures

• Have a Written Program – Approved by Board of Directors or Senior Manager or
Owner

• Train “Relevant” Staff

• Review and Update Program Periodically As Needed (Must report to Senior
Management
At Least Annually)

• Program Must Be “Effective” – i.e. (What is in written program is what you must be doing)

Red Flags Compliant Jumpstart Guide

Also...get the List of 26 Red Flags:
What are the 26 Red Flags In Lending?



The Who, What, Where, When and Why of Red Flags

Webinar Tonight will walk you through all the Steps of
Red Flags Compliance.

Register for the Webinar...

Tues, Aug 4, 2009 8:30 PM - 9:30 PM EDT



IF you can't make it Tonight, Register now for NEXT TUESDAY

AND add it to your Calendar

Tues, Aug 11, 2009 8:30 PM - 9:30 PM EDT
Tuesday, August 11, 2009 8:30 PM - 9:30 PM EDT

Contact Us: GetCompliant@gmail.com

What are the 26 Red Flags of Lending?

As you investigate your need and responsibility to get Compliant
in the Red Flags program, you must be asking...What are the
FTC Red Flags, anyway? Are there 2 or 9 or 100?

Well, there are 26 total Red Flags identified for Compliance.

Not every business is going to need to comply with the same
combination of Red Flags.

What is important is that the Red Flags are reviewed and, if you
find Red Flags that directly relate to your business, then you
MUST, under Federal Law, comply with the Identity Theft Act
known as the FACTACT that covers Consumer Protections.

You must have a plan to safeguard identities and a manual of
ongoing Compliance as a business plan of operations.

Subject: 26 Red Flags In Lending

1. A fraud alert included with a consumer report.

2. Notice of a credit freeze in response to a request for a consumer report.

3. A consumer reporting agency providing a notice of address discrepancy.

4. Unusual credit activity, such as an increased number of accounts or inquiries.

5. Documents provided for identification appearing altered or forged.

6. Photograph on ID inconsistent with appearance of customer.

7. Information on ID inconsistent with information provided by person opening account.

8. Information on ID, such as signature, inconsistent with information on file at financial institution.

9. Application appearing forged or altered or destroyed and reassembled.

10. Information on ID not matching any address in the consumer report, Social Security number has not been issued or appears on the Social Security Administration's Death Master File, a file of information associated with Social Security numbers of those who are deceased.

11. Lack of correlation between Social Security number range and date of birth.

12. Personal identifying information associated with known fraud activity.

13. Suspicious addresses supplied, such as a mail drop or prison, or phone numbers associated with pagers or answering service.

14. Social Security number provided matching that submitted by another person opening an account or other customers.

15. An address or phone number matching that supplied by a large number of applicants.

16. The person opening the account unable to supply identifying information in response to notification that the application is incomplete.

17. Personal information inconsistent with information already on file at financial institution or creditor.

18. Person opening account or customer unable to correctly answer challenge questions.

19. Shortly after change of address, creditor receiving request for additional users of account.

20. Most of available credit used for cash advances, jewelry or electronics, plus customer fails to make first payment.

21. Drastic change in payment patterns, use of available credit or spending patterns.

22. An account that has been inactive for a lengthy time suddenly exhibiting unusual activity.

23. Mail sent to customer repeatedly returned as undeliverable despite ongoing transactions on active account.

24. Financial institution or creditor notified that customer is not receiving paper account statements.

25. Financial institution or creditor notified of unauthorized charges or transactions on customer's account.

26. Financial institution or creditor notified that it has opened a fraudulent account for a person engaged in identity theft.

Source: Federal Trade Commission

Visit our Website for a Free Red Flags Guide

Remember, if Red Flags Rules apply to your business,
This is NOT optional, it is the LAW

GET COMPLIANT

Contact Us: GetCompliant@gmail.com

Monday, August 3, 2009

Red Flag Rules Enforcement

Red Flags Compliance Expert Lee Holden will be giving a
series of Webinars explaining the complicated topic of the
Red Flag Rules Enforcement and postponement by the FTC.

Lee delivered the first Webinar given anywhere regarding
the latest Federal Government postponement of enforcement
of the Red Flags Rule and what it means to your business in a
special Webinar presentation on Tuesday August 4th.

Enforcement had been due to begin August 1st...
the FTC postponed the enforcement just days earlier...

POSTPONEMENT OF ENFORCEMENT OF RED FLAGS--
WHAT DOES THIS MEAN TO YOUR COMPLIANCE???

While the ENFORCEMENT of Red Flags date has now been
pushed back to November 1st...

The COMPLIANCE date is a separate matter. The mandatory
Compliance date has PASSED, therefore, don't be confused
about this...IF YOU ARE REQUIRED TO BE COMPLIANT
YOU ARE ALREADY SUPPOSED TO BE CERTIFIED...
AND, YOU WILL BE HELD ACCOUNTABLE whenever the
Enforcement begins, for violations that take place NOW!

(this post originally made for August 4th Webinar, updated 8/5)

Tuesday August 4th RedFlagsCompliant Rules & the

Red Flags Postponement

plus

Overview for Potential New Affiliates


Please plan on attending a comprehensive overview of

RedFlagsCompliant with Red Flags Expert Lee Holden


8:30pm - 9:30pm EST Tuesday August 4th

On the webinar Lee will be addressing the following:

Whats up with the Red Flag Rule Postponement?
What is the Red Flags Compliance program all about?
What do our customers need to be Compliant?

Open Forum Questions and Answers-Live!

Bring your questions - and we'll get you answers!

Click below to register

UPDATED AUGUST 5: AUGUST 2009 Webinars

HERE are REMAINING AUGUST 2009 LINKS

Click to register:

Tue, Aug 11, 2009 8:30 PM - 9:30 PM EDT


Tue, Aug 18, 2009 8:30 PM - 9:30 PM EDT


Tue, Aug 25, 2009 8:30 PM - 9:30 PM EDT



Three Things You Must Ask BEFORE Starting
The Red Flags Compliance Process.

Complete the form and we will immediately
e-mail you the complete Red Flags Compliance guide
FREE