
The risk assessment required per 12 CFR Part 41 Subpart J (c) determines if an institution has covered accounts and has a formal identity theft prevention program. The risk assessment must be updated periodically based on changes used to open accounts, methods available to access accounts, and the institution’s experience with identity theft.
Our proprietary initial risk assessment includes evaluating BSA requirements, information security, identity theft risk factors and current programs already established inside leading financial institutions. Key gaps and strategies for mitigating identity theft risks are outlined during this process.