STATEMENT OF COMPANY POLICY
IDENTITY THEFT PREVENTION PROGRAM OF
Comporium, Inc.
Fort Mill Telephone Company – d/b/a Comporium Communications
Lancaster Telephone Company – d/b/a Comporium Communications
Community Long Distance – d/b/a Comporium Long Distance
Springboard Telecom, LLC
Catawba Services, Inc.
330 E. Black Street
P.O. Box 470
Rock Hill, SC 29730
DEVELOPED AND IMPLEMENTED PURSUANT TO
THE FAIR AND ACCURATE CREDIT TRANSACTION ACT
The Fair and Accurate Credit Transaction Act (the FACT Act), which amends the Fair Credit Reporting Act (FCRA), establishes numerous requirements that provide protection for the victims of identity theft, provide more information to consumers about credit reports and credit scoring, limits sharing information with affiliates, and protects other consumer information.
The FACT Act applies to financial institutions and “creditors.” Under the FCRA, the term “creditor” has the same meaning as in Section 702 of the Equal Credit Opportunity Act (ECOA), 15 U.S.C. §1691a, which defines "creditor" as "...any person who regularly extends, renews, or continues credit; any person who regularly arranges for the extension, renewal, or continuation of credit; or any assignee of an original creditor who participates in the decision to extend, renew, or continue credit." Additionally, 16 C.F.R. Sec. 681.2(b)(5) states that creditors include "...lenders such as banks, finance companies, automobile dealers, mortgage brokers, utility companies and telecommunications companies" (emphasis added). Concerning "credit," 15 U.S.C. § 1691a defines the term as "...the right granted by a creditor to a debtor to defer payment of debt or to incur debts and defer its payment or to purchase property or services and defer payment therefor." Based on these statutory definitions Comporium, Inc. and its affiliated companies Fort Mill Telephone Company d/b/a Comporium Communications, Lancaster Telephone Company d/b/a Comporium Communications, Community Long Distance d/b/a Comporium Long Distance, Springboard Telecom, LLC and Catawba Services, Inc. (collectively, the “Company”) has determined that it is a “creditor” for the purposes of the FACT Act.
One of the requirements of the FACT Act is that financial institutions and creditors that offer and maintain “covered accounts" develop and implement a written Identity Theft Prevention Program. A "covered account" includes: 1) an account primarily for personal, family, or household purposes that involves or is designed to permit multiple payments or transactions, or 2) any other account for which there is a reasonably foreseeable risk to customers or the safety and soundness of the financial institution or creditor from identity theft. Because the Company maintains accounts for individuals and businesses that are designed to permit multiple payments for the services that the Company offers, the Company does indeed offer and maintain “covered accounts” and thus is required to develop and implement a written Identity Theft Prevention Program and comply with other relevant requirements of the FACT Act.
The FACT Act requires that the Company’s Identity Theft Prevention Program must:
- Identify relevant patterns, practices, and specific forms of activity that are "red flags" signaling possible identity theft and incorporate those red flags in the program;
- Detect red flags that have been incorporated in the program in connection with the opening of covered accounts and existing covered accounts; such as by:
- Obtaining identifying information about, and verifying the identity of, a person opening a covered account, and
- Authenticating customers, monitoring transactions, and verifying the validity of change of address requests, in the case of existing covered accounts.
- Respond appropriately to any red flags that are detected commensurate with the risk presented to prevent and mitigate identity theft in both new and existing accounts; and
- Ensure the program is updated periodically to reflect changes in risks from identity theft.