The Federal Trade Commission announced today that it is once again extending the deadline for enforcing its “Red Flags” Rule, while Congress considers legislation that would affect the scope of entities covered by the Rule. The FTC is delaying enforcement of the Rule until December 31, 2010 in response to a request from members of Congress who are working to finalize legislation that would limit the scope of business covered by the Rule.
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We Were Wrong About the Third Time Being A Charm: FTC Delays Enforcement of Red Flags Rule Yet Again
By Proskauer Rose on
Today, at the urging of Members of Congress, the Federal Trade Commission (“FTC”) announced that it will delay enforcement of its Red Flags Rule for the fourth time. Financial institutions and creditors subject to enforcement by the FTC will now have until June 1, 2010 to develop written policies and…
Red Flag Rules Compliance Deadline Extension Not Grounds to Procrastinate
By Proskauer Rose on
I spoke with Health Leaders Media about the Red Flag Rules and the FTC’s further extension of the compliance deadline.
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Privacy under the 44th President? Will the New Administration Bring a New Playbook?
Posted on
As we prepare to welcome both the 44th President and a revamped Congress to Washington, it is time to consider what privacy under the new administration will look like. Barack Obama polled strongly on the campaign trail as the candidate most likely to advance individual privacy rights, but are the pollsters a good indicator what privacy will look like under the new administration? Here are some of our thoughts about what we may see in the next four years.…
Red Flag Alert — Compliance Deadline is November 1, 2008
By Proskauer Rose on
According to regulations published by the Federal Trade Commission and the federal banking agencies, covered companies that hold any customer accounts must implement identity theft prevention programs that identify and detect “Red Flags” signaling possible identity theft. Companies establishing such programs must create policies and procedures not only to recognize and detect Red Flags, but also to respond to Red Flags by preventing or mitigating potential identity theft. Furthermore, companies must develop reasonable policies and procedures to verify the identity of a customer opening an account, and must also periodically update their identity theft programs. The rules went into effect on January 1, 2008, and businesses must comply by November 1, 2008.
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