Red Flag Guidelines concerning the Identity Theft Prevention Program as established by Immediate Credit Recovery, Inc.

The Federal Trade Commission (FTC), has issued a final rule entitled the "Red Flag Rule" under sections 114 and 315 of the Fair and Accurate Credit Transactions Act (FACTA), that has amended the Fair Credit Reporting Act (FCRA). This rule establishes that certain "financial institutions" and "creditors" that hold "covered accounts" to develop and put in place programs designed to minimize and prevent identity theft. These guidelines indicate that a third party collection services provider such as Immediate Credit Recovery, Inc. may have its own program to prevent identity theft so long as its meets the requirements of the rule.
Immediate Credit Recovery, Inc believes a third party collection services provider does not meet the definition of "financial institution", "creditor" nor do we traditionally service "covered accounts" as defined in this act. Immediate Credit Recovery, Inc. does however take the issue of identity theft very seriously. In addition, Immediate Credit Recovery, Inc. recognizes the need of our client colleges and universities to be assured of red flag compliance on the part of their collection servicers and has developed "Red Flag" compliance as contained in this document.

Risk Assessment:
Ownership, Senior Management and supervisory staff at Immediate Credit Recovery in conjunction with our vendors, legal counsel and human recourses assets conducted a risk assessment to determine where the potential lies concerning risk for identity theft within our scope of operations. This assessment determined:
Immediate Credit Recovery, Inc. is fully compliant with the protections offered by the Graham-Leach-Bailey Act.
Immediate Credit Recovery, Inc. is fully compliant with the protections offered by the Federal Family Educational Loans Act.
Immediate Credit Recovery, Inc. is fully compliant with the protections offered by the Fair Debt Collections Practices Act.
Immediate Credit Recovery, Inc. is fully compliant with the protections offered by the Fair Credit Reporting Act.
Immediate Credit Recovery, Inc. does not originate any type of private loans.
Immediate Credit Recovery, Inc. uses ECSI for processing credit cards. ECSI is PCI certified and regularly provides documentation to that effect to its client base.
Immediate Credit Recovery, Inc. shreds all paper documents originated during the lifespan of an account.

Risk Factors:
As a servicer of third party loans and debts under Red Flag Rules, it was determined that the primary risk factor for identity theft lies within The Address Discrepancy Rule. This regulation applies to users of credit reports who receive a notice of address discrepancy from a consumer reporting agency. A notice of address discrepancy is a notice that the address included in the user's request for a consumer report and the address(es) in the consumer reporting agency's files are substantially different. As a user of consumer reports, Immediate Credit Recovery, Inc. has in place but is not limited to the following procedures designed to "Red Flag" and/or prevent identity theft.

Upon notification of address discrepancy, Immediate Credit Recovery Inc. takes the following steps.
Notification of address discrepancy to our Client College or University Collection action ceases immediately Account is reviewed by senior management and quality control in an attempt to determine the correct information on the consumer Credit Reporting (if applicable) ceases If Immediate Credit Recovery, Inc. is unable to determine with a reasonable degree of certainty the correctness of the supplied information of the consumer, the account in its entirety will be returned to our client

Red Flags:
Based on the identified Risks, Immediate Credit Recovery, Inc has developed sufficient Red Flags which will serve as appropriate indicators of the possibility of identity theft. Immediate Credit Recovery, Inc. remains committed to the privacy and protection of all supplied and developed consumer information contained in our files.