May 2009
In our December 2008 Risk Management Update, Core Compliance & Legal Services, Inc. (“Core Compliance”) 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 August 2009.
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