Red Flag Rule Postponed (Again)

July 2009


On July 29, 2009, the Federal Trade Commission delayed until November 1st the “red flag” rule designed to prevent customer identity theft. In Core Compliance & Legal Services, Inc.’s (“Core Compliance”) May 2009 Risk Management Update, we discussed the proposed “Red Flag Rule”1 which was initially set to go into effect in November 1, 2008, May 1, 2009 and then more recently, on August 1, 2009. While these rules only apply to financial institutions and creditors maintaining covered accounts, Core Compliance provided guidance on the types of investment firms that could fall within these definitions.


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