2009-031-RES-Adopting an identity theft policy in accordance wtih recent amendments to the fair and accurate credit transaction act of 2003

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1. Any account the Utility offers or maintains primarily for personal, family or household purposes, that involves multiple payments or transactions; and 2. Any other account the Utility offers or maintains for which there is a reasonably foreseeable risk to customers or to the safety and soundness of the Utility from Identity Theft. "Identifying information" is defined under the Rule as "any name or number that may be used, alone or in conjunction with any other information, to identify a specific person," including: name, address, telephone number, social security number, date of birth, government issued driver's license or identification number, alien registration number, government passport number, employer or taxpayer identification number, unique electronic identification number, computer's Internet Protocol address, or routing code. III. IDENTIFICATION OF RED FLAGS. In order to identify relevant Red Flags, the Utility considers the types of accounts that it offers and maintains, the methods it provides to open its accounts, the methods it provides to access its accounts, and its previous experiences with Identity Theft. The Utitity identifies the following red flags, in each of the listed categories: A. Suspicious Documents Red Flaqs 1. Identification document or card that appears to - be forged, altered or inauthentic; 2. Identification document or card on which a person's photograph or physical description is not consistent with the person presenting the document; 3. Other document with information that is not consistent with existing customer information (such as if a person's signature on a check appears forged); and 4. Application for service that appears to have been altered or forged. B. Suspicious Personal Identifvinq Information Red Flacts 1. Identifying information presented that is inconsistent with other information the customer provides (example: inconsistent birth dates); 2. Identifying information presented that is inconsistent with other sources of information (for instance, an address not matching an address on a credit report); 3. Identifying information presented that is the same as information shown on other applications that were found to be fraudulent;