FROM: Robert Thompson, General Manager
Originator: Wally Ritchie, Director of Finance
SUBJECT:
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UPDATE TO POSITION TITLES IN THE IDENTITY THEFT PREVENTION PROGRAM
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GENERAL MANAGER'S RECOMMENDATION
recommendation
RECOMMENDATION:
Adopt Resolution No. OC SAN 23-18 entitled: “A Resolution of the Board of Directors of the Orange County Sanitation District Adopting an Update to the Identity Theft Prevention Program in order to comply with the Fair and Accurate Credit Transaction Act of 2003; and Repealing Resolution No. OCSD 09-03”.
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BACKGROUND
This program was created in order to comply with regulations issued by the Federal Trade Commission (FTC) as part of the implementation of the Fair and Accurate Credit Transaction (FACT) Act of 2003. The FACT Act requires that financial institutions and creditors implement written programs which provide for detection of and response to specific activities (“red flags”) that could be related to identity theft.
Recent position title and personnel changes at Orange County Sanitation District (OC San) brought about the need to update this resolution and program to make it current.
RELEVANT STANDARDS
• Comply with Federal Trade Commission regulations
PROBLEM
The current Resolution and program is out of date due to title and personnel changes.
PROPOSED SOLUTION
Update the Resolution and program to reflect current titles and personnel.
TIMING CONCERNS
N/A
RAMIFICATIONS OF NOT TAKING ACTION
OC San will be out of compliance with the FACT Act of 2003.
PRIOR COMMITTEE/BOARD ACTIONS
April 2009 - Adopted Resolution No. OCSD 09-03, Adopting an Identity Theft Prevention Program in order to comply with the Fair and Accurate Credit Transaction Act of 2003.
ADDITIONAL INFORMATION
N/A
CEQA
N/A
FINANCIAL CONSIDERATIONS
N/A
ATTACHMENT
The following attachment(s) may be viewed on-line at the OC San website (www.ocsan.gov) with the complete agenda package:
• Resolution No. OC SAN 23-18 (Redlined)
• Resolution No. OC SAN 23-18 (Final)