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January/February 2012
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October 27, 2008
Articles
"Red Flags" Rule Update — FTC Grants Six Month Delay of Enforcement
The FTC on Wednesday, October 22, 2008, announced that it will suspend the enforcement of the 'Red Flags Rule' until May 1, 2009. Enforcement was to begin on November 1, 2008. This suspension applies to creditors and financial institutions to allow them time to develop and implement written identity theft prevention programs. The suspension comes as a result of FTC outreach efforts to explain the rule which revealed that several industries within the FTC's jurisdiction were uncertain about whether they were covered under the Rule. For some who are generally not required to comply with FTC rules, they were not even aware of the rule's existence and learned too late to be able to comply with the November 1, 2008 deadline. Enforcement of these Rules is inevitable; it is merely delayed to May 1, 2009. This suspension applies only to the Red Flags Rule, not to the rule regarding address discrepancies applicable to users of consumer reports. If your organization uses consumer reports in making decisions regarding employment or extension of credit to customers, you will be required to have in place a plan to deal with address discrepancies by November 1, 2008.
For any questions or for assistance in determining whether your organization is covered by the rules and should develop an identity theft prevention program, please contact any of the Felhaber Health Law attorneys. Information is available on our website, www.felhaber.com.
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Felhaber, Larson, Fenlon & Vogt, P.A. |
Felhaber, Larson, Fenlon & Vogt, P.A. |
www.felhaber.com |
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