Corporate Position on Recent Enforcement Actions
Compliance doesn’t typically garner much attention outside of the financial industry. When the subject does make mainstream headlines, the alarms even put consumers on alert. Being prepared to address such issues is paramount to ensuring ethical practices are followed throughout an organization. Recent news of this magnitude has centered on Bank of America and U.S. Bank as the subjects of enforcement actions by the Consumer Financial Protection Bureau (CFPB) regarding fraud protection services. EZShield has taken the guidance provided by the CFPB to heart, and was fortunately already prepared for the issues that were identified.
EZShield offers a full suite of services that help secure, monitor and restore damage caused by fraud and identity theft. These offerings include products that feature credit monitoring and credit report retrieval similar to the types of products that were discussed in both cases mentioned above.
Problem Practices Identified in the Recent Consent Orders
In the Bank of America case, two types of products were involved: “payment protection products” and “credit monitoring products.” EZShield does not offer any products or services that would classify as “payment protection products.”
In the U.S. Bank case, “Identity Protection Products” were at issue, which featured credit monitoring and credit report retrieval services, among other benefits.
In both recent cases, the banks were held liable for unfair business practices related to the credit monitoring services. Under the Fair Credit Reporting Act, credit report retrieval and credit monitoring products require a written authorization from the consumer granting the institution access to the consumer’s credit file. Until this authorization is received, the consumer’s file cannot be monitored.
Both Bank of America and U.S. Bank or their respective third-party vendors periodically billed consumers for the services, regardless of whether their credit files were actually being monitored. In some instances, this billing triggered further issues, including causing other payments to become rejected or resulting in fees. In other instances, consumers who provided authorization could not be properly identified and matched to some or all of their consumer credit files, meaning that they still did not receive the full benefit of the service.
EZShield’s Fraud Protection Practices
EZShield’s Fraud Protection services have been developed as solutions for our partners’ customers. Our business model focuses on helping our partners meet their business needs through value-added fraud and identity theft protection services. We start our protection with a robust offering that includes:
- Identity Resolution: A dedicated and certified specialist is available to answer questions and assist with resolution in the event of lost wallet, fraud or an identity theft event. A specialist will perform assisted or fully-managed restoration services on behalf of victims and coordinate with a customer’s applicable financial institution and/or other agencies.
- Secure Online Wallet: 24/7/365 online access to a password protected and encrypted website to securely manage sensitive information, thereby reducing the risk of fraud. Examples include identification, credit cards, account numbers, passwords and Social Security numbers.
- Education and Preventative Measures: Access to timely tips and industry best practices that educate consumers and businesses on ways to reduce the risks of identity theft and fraud.
— Monthly Activity Reports: Email communication that includes updated
account information in addition to timely articles and tips addressing
identity theft and fraud.
— Breach and Fraud Alerts: Ongoing emails informing customers how
they can protect themselves in relation to large-scale breaches and
- One-Time Black Market Scan: A one-time scan of online black market chat rooms, websites and databases to ensure that the name, address, phone number and bank account identification associated with a user’s account have not been compromised in the black market channel.
EZShield Credit Monitoring and Credit Report Retrieval Services
In addition to this base level of protection, which includes services to secure, monitor and restore your customer’s identity, we also offer credit and other monitoring services to enhance the level of protection provided. In most of our partnerships, customers are able to add these services on their own and in that process they “activate” the monitoring.
In some cases, financial institutions will offer these monitoring services along with the base fraud protection. EZShield provides clear communications to the end customer to drive them to the website to create an online account and “activate” these monitoring services. Once activated, EZShield verifies that the consumer is actually getting the benefit of the service and is being monitored. EZShield is completely transparent with our partners, reporting exactly when a customer “activates” their services. From there, our partners have everything they need to take the appropriate action with the customer.
Identity Fraud Protection is about delivering peace of mind. At EZShield, we achieve that through a combination of education and tools to help customers secure their identity, monitoring services to help detect any fraudulent activity and fully-managed restoration in the event that something does happen.