FCRA Red Flag Identity Theft Prevention Policy

Updated 06/12/2026

This policy template covers Fair Credit Reporting Act (FCRA) Red Flags and Identity Theft prevention. The following are the key takeaways of the changes:

  1. Minor formatting changes only.

6/12/2026 – Note: On May 19, 2026, President Trump issued Executive Order 14406, Restoring Integrity to America’s Financial System. Subsequently, FinCEN, jointly with the FDIC and OCC, issued Joint Advisory FIN-2026-A002 addressing BSA/AML risks associated with non-work-authorized populations, and the CFPB issued its Statement on Ability to Repay and Immigration Status regarding the consideration of immigration status and repayment risk in underwriting decisions. As of this writing, additional guidance regarding related credit-risk management expectations remains pending.

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