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Re: Comments of Consumers Union on Proposed Regulations on Identity Theft Red Flags and Address Discrepancies Under the Fair and Accurate Credit Transactions Act of 2003

Financial institutions and other creditors play a significant role in facilitating identity theft. A thief generally must open a new account or misuse an existing account in order to turn stolen personal information into cash. Increased care by financial institutions, credit grantors, and other entities that open new accounts will reduce the ease of committing identity theft. The red flag rules will not fulfill this promise if they permit so much discretion to financial institutions and creditors that those entities do not need to increase the levels of care they currently exercise in opening new accounts and in handling transactions in connection with existing accounts.