Privacy Security and Fraud: How to Protect Your Customers

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Safeguarding customers and their financial information is no easy task. Every day it seems as if companies are hacked, customers are duped, and employees are careless. Fraud and financial exploitation, especially of vulnerable and older adults, has grown in number and complexity over the past few years.

Financial institutions can be at the center of these concerns. Not only must institutions comply with laws when providing information to others, it must also be able to protect, as much as it can, customers’ personal information from others. Also, employees at institutions are also one of the first ones to be able to suspect when a customer is being exploited, especially the elderly.

This manual is designed to equip financial institutions with the information they need to be able to protect its customers as well as itself.

This manual will cover:

Sharing Information – the Privacy Rules

  • Gramm-Leach-Blilely(GLB)/Regulation P – Sharing information to non-affiliates
  • FCRA – Sharing information to affiliates; Identity theft; Security Freezes; Fraud/Active Duty Alerts
  • Right to Financial Privacy Act
  • Children’s Online Privacy Protection Act
  • Telephone Consumer Protection Act
  • CAN-SPAM Act

Safeguarding Customers and Customer information from Others/Fraud; How to Handle Breaches

  • Regulation E
  • Section 501(b) of GLB
    • Interagency Guidelines Establishing Standards for Safeguarding Customer Information
    • Interagency Guidance on Response Programs for Unauthorized Access to Customer Information and Customer Notice
  • Interagency Guidelines Establishing Information Security Standards
  • Importance of Identifying Potential Threats- Natural disasters; intention threats (hacking, viruses, etc); unintentional threats(human errors, etc.)
  • Financial Exploitation/Elder Abuse
    • Interagency Guidance on Privacy Laws and Reporting Financial Abuse of Older Adults
    • CFPB – Reporting of Suspected Elder Financial Exploitation by Financial Institutions – Includes summaries of applicable State laws
    • Get Help
    • Economic Growth, Regulatory Relief, Consumer Protection Act – “Senior Safe Act” – immunity from suit
    • BSA/SARs
      • FinCEN Advisory to Financial Institutions on Filing Suspicious Activity Reports Regarding Elder Financial Exploitation
      • CFPB – Suspicious Activity Reports on Elder Financial Exploitation: Issues and Trends

    Discussion of:

    • Risk Assessments
    • Monitoring
    • Compliance testing

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