WHEREAS, the Federal Trade Commission (FTC) adopted rules concerning the adoption of identity theft prevention programs required by the Fair and Accurate Credit Transactions (FACT) Act of 2003, which took effect on January 1, 2008;
WHEREAS, the FTC’s rules (Red Flags Rule) require creditors, such as City utilities, to establish identity theft prevention programs for covered accounts, including utility accounts;
WHEREAS, the Red Flags Rule requires identity theft prevention programs to provide for the identification, detection, and response to patterns, practices, or specific activities, known as “red flags,” that could indicate identity theft;
WHEREAS, City staff has evaluated the number and type of accounts covered by FACT, the likelihood of damage from identity theft, the cost and operational burden in tracking “red flags,” and appropriate responses in the event an identity theft situation develops;
WHEREAS, the Finance Director has prepared the attached Identity Theft Prevention Program for the City, which is commensurate with the size and complexity of the City’s customer accounts and scope of its activities as a creditor for utilities and Municipal Court obligations; and
WHEREAS, FACT requires the Identity Theft Prevention Program to be effective no later than November 1, 2008.
NOW, THEREFORE, BE IT RESOLVED by the Hood River City Council that the Identity Theft Prevention Program attached to this Resolution is adopted.
Approved by the Hood River City Council the 27th day of October, 2008, to take effect November 1, 2008.
Linda Streich, Mayor
Jennifer McKenzie, City Recorder