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FAQs
Frequently
Asked Questions About FinCrime
What is FinCrime?
FinCrime.com
is a powerful new on-line tool to help prevent financial
institution fraud, such as check fraud, counterfeit checks,
identity fraud, robberies, new account fraud and more.
This loss-prevention/anti-crime service is a benefit brought
to you as a member of the Ohio Credit Union League.
FinCrime.com is only available to League-affiliated
credit unions.
FinCrime.com is sponsored by the Ohio Credit Union League in
cooperation with the Ohio Bankers League and the Ohio
Attorney General. Member financial institutions and law
enforcement agencies throughout Ohio and eleven other states
participate by sharing vital information on-line relating to
recently committed (or attempted) financial institution
crimes. Stored in FinCrime’s central database, these crime
incidences are immediately shared with other participating
financial institutions and law enforcement agencies through
e-mail alerts and viewing on-line. The system even permits
photos of perpetrators to be uploaded and shared with
others.
How does FinCrime work?
FinCrime provides a communication vehicle for financial
institutions and law enforcement. FinCrime functions as a
clearinghouse of information where each participant submits
fraud data into a central repository. FinCrime allows users
to search the database of fraud incidents to find incidents
that have data in common with their own cases.
Who can use FinCrime?
FinCrime can be used by any authorized law enforcement
agency, financial institution or approved retailer. All
users must be authenticated and approved by the network
administrator or one of the sponsoring associations. The
Ohio Credit Union League makes the service available to
affiliated credit unions through its Web site at
www.OhioCreditUnions.org.
What does FinCrime accomplish?
By providing a confidential and secure way to share
information about fraudulent transactions, participating
financial institutions are made aware of fraudulent activity
in their area, usually sooner than they would be able to
identify it by themselves. This early awareness allows them
to take action to prevent fraud losses. Also, the shared
database provides opportunities to build fewer but larger
"multi-bank" cases out of smaller individual losses, helping
financial institutions and law enforcement focus on
organized crime and repeat offenders.
How will law enforcement benefit?
First and foremost, FinCrime helps consolidate numerous
small, individual victim cases into fewer, stronger
"multi-victim" cases. This focuses law enforcement on
perpetrators that are doing the most serious damage to the
industry as a whole and allows them to use their limited
resources more effectively. This more efficient use of law
enforcement resources results in overall loss reduction for
financial institutions, as professional criminals find
financial institution fraud more difficult, more risky, and
less profitable to pursue.
How is data entered into the system?
Individual cases can be entered into the system via a form
on the web site, or multiple cases can be loaded into the
FinCrime database via batch upload process.
How can credit unions search the data?
The real power of the system comes from the ability to
search the data in a number of ways.
FinCrime’s
sophisticated searching capabilities automatically searches
and cross-matches reported crimes, and sends alerts to all
involved. The ability to cross-reference perpetrator’s
names, aliases, license plate numbers, identification used,
financial instruments used, etc., allows law enforcement
agencies to identify multi-institution perpetrators, and
aids in criminals’ apprehension and prosecution.
Equally important is the credit union’s ability to search
the database on various fields or combination of fields,
assisting in finding matches with FinCrime’s database or
other suspected fraud encounters at the credit union.
Can anyone change the data that credit unions have loaded?
With the exception of "follow up" information, only the
person that posted the incident has the ability to modify
the information that has been posted. Follow-up information
can be added to an incident by anyone, but is intended to be
used by law enforcement to add additional information as the
investigation proceeds. The owner of the incident is
notified by e-mail when follow up information is added.
What data is stored?
Data stored includes information on the date and type of
crime, information from the financial document used, all
relevant information from the ID used by the suspect, as
well as information regarding the investigating
officer/agency.
Does the system help credit unions contact other
investigators?
The name and contact information of the person posting the
incident as well as the investigating officer, along with
the case number are stored in the database.
What else does the system do to help credit unions match
incidents?
At the time that an incident is posted to the network, the
network will automatically check the incident against all
other incidents in the database. If a match is found with
another incident both you and the person that posted the
matching incident are notified of the matching elements via
e-mail. The system also contains a feature that will allow
you, or law enforcement to link two incidents together when
the system may not otherwise be able to do so. This is
useful when one the incidents involves someone using a known
alias.
Does the system distinguish or denote victims’ names?
An indicator can be placed on all name fields within the
database to show that this person is the victim of the crime
rather than the perpetrator.
Does FinCrime conflict with FinCEN SAR reporting
requirements?
The Bank Secrecy Act prohibits a financial institution, its
directors, officers, employees or agents from disclosing to
any person involved in the transaction that a SAR has been
filed. SARs must be filed only on certain transactions that
are suspicious in nature, involve potential money laundering
or violations of the Bank Secrecy Act when aggregate dollars
involved in the transactions exceed reporting thresholds.
The BSA does not prohibit information contained in a SAR to
be shared on a voluntary basis with other persons or law
enforcement, so long as the fact that the SAR has been filed
is not disclosed.
What implications does the Fair Credit Reporting Act (FCRA)
have on FinCrime and FinCrime Participants?
The FCRA contains certain exclusions from the definition of
"consumer report." One such exclusion is any report
containing information solely as to transactions or
experiences between the consumer and the person making the
report. Under that exclusion, information published by a
member of FinCrime that relates solely to the transactions
or experiences between the consumer and the person making
the report would not be a consumer report within the meaning
of FCRA, and such a report will not violate FCRA.
Accordingly, members of FinCrime should limit the
information published to specific experiences between the
consumer and the financial institution publishing the
information on FinCrime.
Does FinCrime Participants' information contribution
conflict with the Gramm-Leach-Bliley Act (GLBA)?
GLBA generally requires protection of the security and
confidentiality of customer records and information.
However, GLBA contains certain exceptions, including §
502(e)(3) which provides as follows: "GLBA shall not
prohibit the disclosure of nonpublic personal information to
protect against or prevent actual or potential fraud,
unauthorized transactions, claims or other liability." Since
FinCrime members will provide information that is for the
purpose of protecting or preventing actual or potential
fraud, unauthorized transactions, claims, or other
liability, such sharing of information is specifically
permitted under GLBA.
Would use of the FinCrime system be in conflict with any
aspects of the USA Patriot Act?
Section 314(b) of the USA PATRIOT Act allows financial
institutions to voluntarily share information with each
other after first filing notice with FinCEN that they will
participate in sharing. However, this voluntary sharing
under the PATRIOT Act covers sharing of information related
exclusively to terrorist financing and money laundering.
Since FinCrime is a database primarily designed to share
info related to check fraud, it's unlikely that it will be
impacted by the requirements of Section 314(b).
Who should have access to FinCrime?
FinCrime.com is a secure system, requiring Ohio Credit Union
League approval of each credit union staff person requesting
access. Generally, one to two individuals per credit union
should have access to the FinCrime.com site (or possibly one
person per branch location). This person is usually the
security officer, internal auditor, CEO, or other authorized
person.
How does our credit union sign up for FinCrime?
It’s easy to sign up. Go to
www.OhioCreditUnions.org and click on “FinCrime”
(or go directly to
www.FinCrime.com). Complete an on-line profile,
indicating the type of activity and geographic regions from
which you wish to receive e-mail alerts. Once you receive
approval by e-mail from the League (required for security
purposes), simply log on to FinCrime.com and review a short
on-line user’s guide.
Who do we
call if we have questions?
Please call the Ohio Credit Union League’s Research &
Information Department at (800) 486-2917 or (614) 486-2917.
Once you have been approved for access, you may also refer
to a short on-line user’s manual at
www.FinCrime.com. |
