In our December 2008 Risk Management Update, Core Compliance & Legal Services,
Inc. ("CCLS") discussed the Federal Trade Commission's ("FTC") proposed "Red Flag
Rules."1 As a brief recap, the "Red Flag Rules" require financial institutions and
creditors with covered accounts to develop and implement written programs for the
detection, prevention, and mitigation of identity theft.2 Although the Red Flag Rules took
effect as of November 2008, the FTC has delayed the enforcement of the rules until
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