Banking institutions were required to strengthen, document and implement new awareness programs by Nov. 1. This requirement has been one of the biggest challenges faced by institutions this year. The Office of Thrift Supervision revealed its examination procedures for ID Theft Red Flags Rule compliance in this piece: OTS revealed 15 separate examination steps related to three principle elements of the new rule: Identity Theft/Red Flags; Change of Address; Address Discrepancies; and training – including for board members – is a significant component of these procedures.”]