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 (“CCLS”) 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, CCLS provided
guidance on the types of investment firms that could fall within these definitions.


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