The Federal Trade Commission ("FTC") announced on July 29, 2009, that the agency would once again delay enforcement of the "Red Flags Rule"—this time until November 1, 2009. The red flag rules and guidelines require financial institutions and creditors to formulate and implement identity-theft prevention programs. In a recent enforcement policy statement, the FTC explained that the new rules applied to a wide range of industries and entities, many of which were unaware until very recently that they would be considered a "financial institution" or "creditor" for the purposes of the rules. Many of these businesses were generally not required to comply with FTC rules in other contexts and had not been aware of the red flag rules.
For more information, please see our previous Alerts on the topic by clicking on the links below:
"Red Flag" Rules May Snare Unsuspecting Businesses
Feds Force Businesses to Implement Identity Theft Prevention Measures by Fall 2008
For Further Information
If you have any questions regarding these regulations, including how they may affect your company, please contact Sandra A. Jeskie, a member of the Information Technologies and Telecom Practice Group or the lawyer in the firm with whom you are regularly in contact.
Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.