The Fair and Accurate Credit Transactions Act of 2003 amended the Fair Credit Reporting Act, and required the Federal Trade Commission (FTC), together with other regulatory agencies, to issue and enact regulations requiring financial institutions and creditors to develop and implement written identity theft prevention programs. These regulations apply to the University because it is a “creditor”, which is defined as any person who defers payment for services rendered. Instances of such activity would be permitting medical patients to pay for services over time, permitting students to pay tuition throughout the semester rather than requiring payment in full at the beginning of the semester, and participating in the Federal Family Education Loan (FFEL) and Perkins student loan programs.
The University has developed and implemented a program for the identification, detection, prevention and mitigation of theft of personally identifiable financial information in covered accounts, which are defined as those accounts where multiple payments or transactions are permitted. An Identity Theft Prevention Program committee has been formed to develop an Identity Theft Prevention Program (ITPP). This committee will also identify the areas where covered accounts are held by the University, and will ensure University personnel are appropriately trained on the ITPP for all departments, schools and areas where covered accounts are located.
Under the University of Missouri’s ITPP, the Vice President for Finance and Administration is the Program Administrator, with the ITPP committee reporting directly to this individual. Under the ITPP, the Vice President for Finance and Administration will report annually to the Board of Curators on the effectiveness and continued implementation of the program.
The University of Missouri’s ITPP was approved by the Board of Curators on February 6, 2009.