Implementation Checklist (ChoicePoint (FTC 2006))¶

A practical rollout plan with measurable proof for fraudulent onboarding risk reduction and accountable control governance.

0–30 days (stabilize + baseline)¶

Inventory onboarding workflows and access points for consumer records
Baseline customer-verification controls and exception handling
Create formal approvals for high-risk onboarding control changes

Deliverables - Onboarding control inventory with owners - Verification-control change SOP - Onboarding event logging coverage report

30–60 days (control effectiveness)¶

Deploy drift checks for onboarding and access control settings
Perform least-privilege review for onboarding/data-access roles
Enable detections for suspicious account origination activity

Deliverables - Control drift dashboard and response workflow - IAM review evidence with stale-access remediation - Fraud/onboarding detection rule test records

60–90 days (evidence readiness)¶

Conduct 48-hour evidence-pack readiness drill for FTC-facing artifacts
Add independent testing checkpoints for onboarding controls
Publish quarterly governance update on fraud-prevention control effectiveness

Deliverables - Evidence checklist with retrieval owners - Mock regulator response drill report - Governance reporting template with KPI pack

Ongoing metrics (prove it's real)¶

% onboarding exceptions with documented approvals
Time to remediate high-risk onboarding control gaps
Privileged entitlement reduction rate
Coverage % for onboarding/auth logs
Age of unresolved critical fraud-risk findings