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responsible for reviewing reports prepared by City of Colton's staff regarding City of Colton's <br />compliance with FACTA and the Red Flag Rules requiring the implementation of an Identity <br />Theft Prevention Program. <br />IV. COMPLIANCE REPORTS TO BE PREPARED BY CITY OF COLTON STAFF <br />The FACT ACT Committee will designate City of Colton staff involved with the <br />implementation of the Program to prepare reports regarding City of Colton's compliance with <br />FACTA and the Red Flag Rules requiring the implementation of an Identity Theft Prevention <br />Program. The reports should address material matters related to the Program, such as the <br />following: <br />(a) The effectiveness of the City of Colton's policies and procedures to address the <br />risk of identity theft in connection with opening customer accounts, as well as <br />with existing accounts. This includes identifying any issues related to identifying, <br />detecting and responding to Red Flags; <br />(b) Third -party service provider arrangements; <br />(c) Significant incidents of identity theft or Red Flag detection, and City of Colton's <br />responses to those incidents; <br />(d) Recommendations for material changes to the program to ensure that customer <br />accounts are adequately protected from the risk of identity theft. <br />The reports should be prepared at least annually for review by the FACT ACT <br />Committee and the City Council. <br />V. RED FLAGS IDENTIFIED BY CITY OF COLTON <br />In identifying the Red Flags applicable to City of Colton's customer accounts, City of <br />Colton considered the following risk factors: <br />(a) The types of accounts City of Colton maintains; <br />(b) The methods City of Colton provides to open customer accounts; <br />(c) The methods City of Colton provides to access customers' accounts; <br />(d) City of Colton's previous experiences with identity theft in connection with the <br />customer accounts. <br />The Red Flags identified in this Program have been incorporated from sources, which <br />include supervisory guidance, past incidents of identity theft, and changes in methods of identity <br />theft risk. <br />2 <br />