US Mortgage Lenders LLC Red Flag Procedures
(Identity Theft and Address Discrepancy Program)


Federal Law requires our Company to establish procedures for the prevention of identity theft and address discrepancies. Red Flags are used to detect identity theft.


Identity theft means fraud committed or attempted using the identifying information of another a person without authority.

Red Flag

A red flag means a pattern, practice or specific activity that indicates the possible existence of identity theft.

The Program

US Mortgage Lenders LLC establishes an Identity Theft Prevention Program to detect,
prevent and mitigate identity theft. The Program shall include reasonable policies and
procedures to:

  1. Identify relevant red flags for covered accounts it offers or maintains and incorporates those
    red flags in the program;
  2. Detect red flags that have been incorporated into the Program;
  3. Respond appropriately to any red flags that are detected to prevent and mitigate identity
    theft; and
  4. Ensure the Program is updated periodically to reflect changes in risks to customers and to
    the safety and soundness of the creditor from identity theft.

Identification of Relevant Red Flags

1. Employees shall review for relevant red flags from the following categories as appropriate:
  • Alerts, notifications, or other warnings received from consumer reporting agencies or service providers, such as fraud detection services;
  • The presentation of suspicious documents;
  • The presentation of suspicious personal identifying information;
  • The unusual use of, or other suspicious activity related to, a covered account; and
  • Notice from customers, victims of identity theft, law enforcement authorities, or other persons regarding possible identity theft in connection with covered accounts.

Detection of Red Flags

The Program address the detection of red flags when taking of a loan
application by:

  1. Obtaining identifying information about, and verifying the identity of, a person opening a
    covered account; and
  2. Authenticating customers, monitoring transactions, and verifying the validity of change of address requests in the case of existing covered accounts.


The Program shall provide appropriate responses to detected red flags to prevent and
mitigate identity theft. The response shall be commensurate with the degree of risk posed.
Appropriate responses may include:

  1. Monitor a loan application for evidence of identity theft;
  2. Notify Senior Management
  3. Contact the customer using the phone directory;
  4. Change any passwords, security codes or other security devices that permit access to a covered account;
  5. Not open take a loan application;
  6. Terminate an existing loan application;
  7. Notify law enforcement; or
  8. Determine no response is warranted under particular circumstances.

Duties Regarding Address Discrepancies

If the organization receives a notice of address discrepancy from a nationwide consumer reporting agency indicating the address given by the consumer differs from the address contained in the consumer report, the mortgage loan originator shall take the appropriate action to form a reasonable belief that a credit report relates to the consumer for whom it was requested.

An Employee may reasonably confirm that an address is accurate by any of the following means:

  1. Verification of the address with the consumer;
  2. Review of the company’s records;
  3. Verification of the address through third-party sources; or
  4. Other reasonable means.