Insider Viewpoints by Roy DeLoach, Chief Executive Officer, NAMB

By May 1, 2009, mortgage brokers are required to be in compliance with the Identity Theft Red Flags & Address Discrepancies Final Rule (Red Flags Rule) under the FACT Act. The Red Flags Rule requires you to have a written Identity Theft Prevention Program implemented in your office, as well as provide identity theft detection training for your employees.

NAMB Summary – Red Flag Rule

      The Red Flags Rule requires companies to:

• Develop a written program to detect and respond to potential ID theft.
  Red Flag Rule detection programs should be appropriate to your company. They can be complex customized solutions or simplistic templates, but must be complete in scope and adhered to by your company. Detection of identity theft can be accomplished through 3rd-party solutions.
  
• Train employees on detection.
  While the law encourages everyone from “the boardroom to the mailroom” to be trained, you must at least train employees who are in a position to detect ID theft. This may be processors, Loan Officers, Sales Managers, and more, depending on your operation. Your plan will address this.
  
• Update and review your program annually.
  The written program must be approved by your leadership annually.
  After careful evaluation of numerous companies providing tools for the written Identity Theft Prevention Program and employee training modules, NAMB has partnered with Majestic Security, LLC and Microbilt, Inc to offer the most beneficial options for NAMB members. Each vendor has its advantages for members of varying size and complexity. Please review both to determine which solution is right for your company. For more information, please click the Red Flag Compliance button below.