Red Flags Rule Office Policy

The Federal Trade Commission (FTC) created the Red Flags Rule in response to the increasing volume of identity theft. It is a federal requirement that qualifying businesses, like real estate / property management companies, have a written policy to educate staff and combat identity theft.

Real estate / property management companies collect “identifying information,” which includes names and numbers that can be used alone or with other information to identify a specific person. Your company most likely collects one or more of the following from your clientele:

  • social security number
  • date of birth
  • driver’s license
  • passport
  • alien registration
  • Tax ID’s (EIN, TIN)

The Red Flags Rule Office Policy helps you comply with the FTC requirements, protect your clientele from identity theft, and train your personnel on this important issue. Find out more about the Red Flags Rule.

This product includes:

  • the Red Flags Office policy manual
  • 5 supporting forms
  • product instructions

PM Made Easy products are copyright protected and non-transferable. Only the buyer or buyer’s representatives are authorized to modify and use the purchased content.

Red Flags Office Policy Manual 

Manual Format: The Red Flags Manual for Property Management is created in Microsoft Word® so you can easily customize the contents with your local / state requirements, your specific business practices, and your company brand identity.

Product Instructions: All PM Made Easy products include the 25+ pages of Product Instructions in a PDF Format. It is important to read the Product Instructions designed to save hours of time and frustration before you start the manual. Make sure to save an original copy and place in a secure location.

Special notes: The manual uses (PM Made Easy) & (PMME) throughout as an example of a company name and initials. It is simple to replace them with your company name and initials in the manual document, using the Microsoft Word® feature, “Find & Replace,” which is included in the Instruction pages of the workbook. Red Text indicates areas that you should definitely change to your company, state, or local information

Table of Contents: The following pages show the Table of Contents for the Red Flags Manual for Property Management. This Table of Contents is subject to change when necessary. All manuals created by PM Made Easy have a built-in Table of Contents, which you can automatically update after making changes to the text in the manual.

Forms: With this product, there are currently 5 forms.

Red Flags Office Policy Manual


What is the Red Flags Rule?

Does the Company Need to Comply?

Reasons we are at risk

What do we need to do?

1 – Identifying Relevant Red Flags 

2 – Detect Red Flags 

Red Flags – Behavior

Red Flags – Confidentiality

Red Flags – Taking Identification

Red Flags – Application Documentation

Red Flags – Running a Credit Report

Red Flags – All Credit Card payments

Red Flags – Prior to Renting

Red Flags – After Renting

Red Flags – Sales Activity

3 – Prevent and Mitigate Identity Theft 


Personal information disclosure

Office Security

Resolving Red Flags Rule Issues

Applicable Service Providers

4 – Maintain and Update the Red Flags Rule Program 

Personnel Cooperation and Responsibilities

Personnel Training

Policy Review

EXCERPTS from the Red Flags Manual

Reasons we are at risk

The FTC defines identifying information as any name or number that may be used, alone or in conjunction with any other information, to identify a specific person, including, but not limited to: name, social security number, date of birth, official state or government driver’s license or identification number, alien registration number, government passport number, employer or taxpayer identification number. 1

If any of the following does not apply to your company, delete or reword as necessary.

Because of this definition, Management has identified areas where it is necessary to have a policy in our office to cover the Red Flags Rule.

  • (Company Name) interacts with many people that we do not personally know and requires various forms of identification to rent to unknown parties,


1 Fighting Fraud with the Red Flags Rule, a How-to Guide for Business, Federal Trade Commission

Red Flags – Behavior

Although these red flags may not be identifying information, Personnel should watch for behavioral signs as red flags could indicate other problems related to identity theft.

  • The applicants exhibit nervousness or unusual sweating
  • The applicants become difficult and/or abusive.
  • The applicants are not what they represent.
  • The applicants will not fill out the application completely.
  • The applicants will not supply required documentation.


Personal information disclosure

Personnel need to be aware of the importance of protecting all personal information or identifying information and comply with the following:

  • Personnel are to keep all information with identifying information secure at all times.
  • Personnel are not to leave documentation unattended.

All documentation should be stored properly before:

  • Leaving their work station
  • Leaving the office for any reason, such as lunch, end of word day, or special appointments
  • Examples, applications should not be left unattended on the reception desk; listing and sales information should not be left unattended on Sales Agents desk or Sales Agent’s assistant’s desk.

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