E-700 Identity Theft Prevention

The College shall have an Identity Theft Prevention Program under the Federal Trade Commission's Red Flags Rule, which implements Section 114 of the Fair and Accurate Credit Transactions Act of 2003. The Program shall be designed to detect, prevent, and mitigate identity theft in connection with a covered account and to provide for continued program administration. The Program shall include reasonable policies and procedures to:

• Identify relevant red flags for covered accounts and incorporate those red flags into the program.

• Detect red flags that have been incorporated into the Program.

• Respond appropriately to any red flags detected to prevent and mitigate identity theft.

• Ensure the Program is updated periodically to reflect changes in risks to Students and to protect the safety and soundness of the creditor from identity theft.

While reasonable efforts will be made to detect, prevent, and mitigate identity theft, the College makes no representations or warranties that the Program will ensure the absence of identity theft or prevent financial losses. All warranties against loss, either express or implied, are hereby disclaimed. Furthermore, the College will not be liable for direct, indirect, or consequential damages.