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1. Any account the Utility offers or maintains primarily for personal, family or household <br />purposes, that involves multiple payments or transactions; and <br />2. Any other account the Utility offers or maintains for which there is a reasonably <br />foreseeable risk to customers or to the safety and soundness of the Utility from Identity <br />Theft. <br />"Identifying information" is defined under the Rule as "any name or number that may be used, <br />alone or in conjunction with any other information, to identify a specific person," including: <br />name, social security number, date of birth, government issued driver's license or identification <br />number, alien registration number, government passport number, employer or taxpayer <br />identification number, unique electronic identification number, or routing code. <br />III. IDENTIFICATION OF RED FLAGS. <br />In order to identify relevant Red Flags, the Utility considers the types of accounts that it <br />offers and maintains, the methods it provides to open its accounts, the methods it provides to <br />access its accounts, and its previous experiences with Identity Theft. The Utility identifies the <br />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 pattern <br />or activity. <br />B. Suspicious Documents <br />Red Flags <br />1. Identification document or card that appears to be forged, altered or inauthentic; <br />2. Identification document or card on which a person's photograph or physical description is <br />not consistent with the person presenting the document; <br />3. Other document with information that is not consistent with existing customer <br />information (such as if a person's signature on a check appears forged); and <br />4. Application for service that appears to have been altered or forged. <br />C. Suspicious Personal Identifying Information <br />3 <br />