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"a pattern,practice, or specific activity that indicates the possible existence of <br /> Identity Theft." <br /> According to the Rule, a municipal utility is a creditor subject to the Rule <br /> requirements. The Rule defines creditors to "include finance companies, automobile <br /> dealers,mortgage brokers, utility companies, and telecommunications companies. <br /> Where non-profit and government entities defer payments for goods or services, <br /> they,too, are to be considered creditors." <br /> All the Utility's accounts that are individual utility service accounts held by <br /> customers of the utility whether residential, commercial or industrial are covered by <br /> the Rule. Under the Rule, a"covered account is: <br /> 1. Any account the Utility offers or maintains primarily for personal, family or <br /> household purposes,that involves multiple payments or transactions; and <br /> 2. Any other account the Utility offers or maintains for which there is a reasonable <br /> foreseeable risk to customers or to the safety and soundness of the Utility from <br /> Identity Theft. <br /> "Identifying information" is defined under the Rule as "any name or number that may <br /> be used, alone or in conjunction with any other information,to identify a specific <br /> person," including: name, social security number, date of birth, government issued <br /> driver's license or identification number, alien registration number, government <br /> passport number, employer or taxpayer identification number,unique electronic <br /> identification number, or routing code. <br /> 3.0 Identification of Red Flags <br /> A. In order to identify relevant Red Flags,the Utility considers the types of accounts that <br /> it offers and maintains,the methods it provides to open its accounts,the methods it <br /> provides to access its accounts, and its previous experiences with Identity Theft. The <br /> Utility identifies the following red flags, in each of the listed categories: <br /> a. Notifications and Warnings from Credit Reporting Agencies <br /> Red Flags <br /> 1. Report of fraud accompanying a credit report; <br /> 2. Notice or report from a credit agency of a credit freeze on a customer or applicant; <br /> 3. Notice or report from a credit agency of an active duty alert for an applicant; and <br /> 4. Indication from a credit report of activity that is inconsistent with a customer's usual <br /> pattern or activity. <br /> b. Suspicious Documents <br /> Red Flags <br /> 112 <br />