In this slidecast, we look at information security through the unique lens of the mortgage industry, to understand the increased risk - and greater opportunity - that a strong Red Flag Rules program has for your mortgage business. Also a great primer for anyone thinking about buying a home, to learn how the mortgage industry uses your PII, and how you can protect it, through the application process.
4. Our goals today
‣ To give you the WHAT…
‣ The FTC’s Red Flag Rules
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5. Our goals today
‣ To give you the WHAT…
‣ The FTC’s Red Flag Rules
‣ ...review the HOW…
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6. Our goals today
‣ To give you the WHAT…
‣ The FTC’s Red Flag Rules
‣ ...review the HOW…
‣ demo the idBUSINESS Red Flag Compliance
Module
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7. Our goals today
‣ To give you the WHAT…
‣ The FTC’s Red Flag Rules
‣ ...review the HOW…
‣ demo the idBUSINESS Red Flag Compliance
Module
‣ but also give you the WHY
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8. Our goals today
‣ To give you the WHAT…
‣ The FTC’s Red Flag Rules
‣ ...review the HOW…
‣ demo the idBUSINESS Red Flag Compliance
Module
‣ but also give you the WHY
‣ Why information security is an
OPPORTUNITY, not a burden
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18. The Opportunity
‣ There is a unique opportunity to grow a
mortgage business by leveraging strong
information security policy and sharing it with
borrowers
‣ Build trust with borrowers
‣ Strengthen employee relationships
‣ Tighten lender/broker operations
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19. The Risk
‣ The mortgage industry has a unique burden to
protect borrower information
‣ Government mandate for regulation
‣ Financial industry scrutiny
‣ The Consumer’s Age of Transparency
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20. The facts
30%
40%
60%
70%
Business has suffered breach Thief is employee or knows employee
Business has yet to incur a breach Thief is unknown
• Since 2/15/05, over 251,000,000 Americans have had
identities or other personal information compromised
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21. The facts
The average breach and its impact on customer confidence is growing.
58% of customers will
lose confidence in your
business after a breach.
31% of your customers
will immediately cease
doing business with
you following a breach.
Source: Ponemon Institute, 2008.
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23. The Red Flag Rules
‣ Sections 114 & 315 of the Fair and Accurate
Credit Transactions Act
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24. The Red Flag Rules
‣ Sections 114 & 315 of the Fair and Accurate
Credit Transactions Act
‣ Applies to you if:
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25. The Red Flag Rules
‣ Sections 114 & 315 of the Fair and Accurate
Credit Transactions Act
‣ Applies to you if:
‣ you hold “covered accounts”
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26. The Red Flag Rules
‣ Sections 114 & 315 of the Fair and Accurate
Credit Transactions Act
‣ Applies to you if:
‣ you hold “covered accounts”
‣ your customer records present a “reasonably
foreseeable risk of identity theft”
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27. Why are mortgage cos.
COVERED ENTITIES?
‣ Deferring payment
‣ The mortgage process is by definition a
deferred payment and credit-granting
process
‣ Reasonably foreseeable risk
‣ Borrower files are a treasure trove
‣ Each record worth between $80-300 each*
* Source: Black Market Identity Auction attended by Net Reaction mole, 2008.
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30. Red Flag
REQUIREMENTS
1. A Written Information Security Program
2. Controls to prevent and mitigate the risks associated with
identity theft
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31. Red Flag
REQUIREMENTS
1. A Written Information Security Program
2. Controls to prevent and mitigate the risks associated with
identity theft
3. Must be administered by a board of directors or a member
of senior management
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32. Red Flag
REQUIREMENTS
1. A Written Information Security Program
2. Controls to prevent and mitigate the risks associated with
identity theft
3. Must be administered by a board of directors or a member
of senior management
4. Must deliver compliance report on at least an annual basis
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33. Red Flag
REQUIREMENTS
1. A Written Information Security Program
2. Controls to prevent and mitigate the risks associated with
identity theft
3. Must be administered by a board of directors or a member
of senior management
4. Must deliver compliance report on at least an annual basis
5. Must contain mechanism to train employees
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34. Red Flag
REQUIREMENTS
1. A Written Information Security Program
2. Controls to prevent and mitigate the risks associated with
identity theft
3. Must be administered by a board of directors or a member
of senior management
4. Must deliver compliance report on at least an annual basis
5. Must contain mechanism to train employees
6. Must contain an incident response capability
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35. Red Flag
REQUIREMENTS
1. A Written Information Security Program
2. Controls to prevent and mitigate the risks associated with
identity theft
3. Must be administered by a board of directors or a member
of senior management
4. Must deliver compliance report on at least an annual basis
5. Must contain mechanism to train employees
6. Must contain an incident response capability
7. Must ensure that vendors and suppliers are also compliant
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36. “What happens
if I don’t comply?”
• Legal liability
– Civil lawsuits, class-action litigation
• Government penalties
– FTC & State enforcement
• Damage to brand reputation and borrower trust
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37. The solution
‣ The idBUSINESS Red Flag Compliance Module
‣ Built on real-world forensic fieldwork
‣ Includes tools & benefits that actively involve
employees in your compliance efforts
‣ Transitions information security from a
compliance issue into a competitive advantage
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40. The Red Flag
Compliance Module
‣ Risk Assessment tool provides ranking of your
company in 12 key focus areas
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41. The Red Flag
Compliance Module
‣ Customizable checklist of 26 Red Flags to meet
requirements of FACT Act
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42. The Red Flag
Compliance Module
‣ Employee training automated & easy, integrates
automatically with your compliance report
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43. The Red Flag
Compliance Module
‣ Ability to evaluate supplier compliance practices using
our proprietary Vendor Integrity Assessment
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44. The Red Flag
Compliance Module
‣ Access individual identity recovery protection using
FraudStop and Restore from ID Experts
‣ Available as employee benefit, cafeteria-style add-on,
customer blanket, or new revenue stream
‣ In the event of a breach, one-click access to best-in-
breed data breach services and forensic services
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45. Mortgage Industry
BENEFITS
‣ NAMB Preferred Provider
‣ www.majesticsecurityidsafe.com
‣ Because We Care
‣ www.mortgagedashboard.com
‣ Mortgage Insurance Agency
‣ www.mtgins.com
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46. “Can’t I do this myself?”
• A self-written policy meets the letter of the law, but
leaves gaps:
– No vendor integrity assessment
– No employee training, just signature line
– No mitigation of damages in the event of an incident
• Who will you call when you have a question?
• No context of how Red Flag Policy fits into your business
– What’s worth doing is worth doing right.
– Missing an opportunity to GROW your business
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47. So I’m compliant...
‣ NOW WHAT?
‣ Don’t let it sit on a shelf
‣ Talk to your employees
‣ Talk to your borrowers
‣ Use your policy as a business-building tool
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