Red Flags Rule - Update as of April 25, 2011
FTC Red Flags Rule is enforceable as of 12/31/10 Do YOU need to comply with the Red Flags Rule?
If so, are you complying with the Red Flags Rule?
NEW UPDATE:
Federal Trade Commission (FTC)
Attorney Tiffany George, in a recent discussion with
representatives of NACM,
including NACM lobbyist Jim Wise,
Bruce Nathan, Esq. and Wanda Borges, Esq.,
offered the clearest guidance yet on
the extent to which the “Red Flags” Rules apply to business to
business (B2B) transactions involving trade creditors.
Read more...
Click here
to find out in the FTC’s How-To Guide for Business.
(updated as of 2/10/11)
Memo from Wanda
Borges, Esq.
(1/6/2011)
Regarding the Federal Trade Commission – Red Flags
Rule.
Click here to read
the full memo.
DAL has put together more Red Flag Resources
such as how to's, templates and more,
go to
DAL's
Business
Resource page to the
Red.
Update From the Credit Research Foundation:
Congress has passed legislation further clarifying the “Red
Flags Rule”. The current FTC enforcement date of the rule is 12/31/2010. On
this date, most organizations who grant credit are expected to be compliant.
Based on the passage of the recent congressional legislation a
press release dated December 8th quoting FTC chairman Jon Leibowitz,
provided an insight into the current thinking on the part of the FTC as to its
role in enforcement of the Red Flags Rule. It had this to say…
“The Rule doesn’t require any
specific practice or procedures. It gives businesses the flexibility to tailor
their written ID theft detection program to the nature of the business and the
risks it faces. Businesses with a high risk for identity theft may need more
robust procedures – like using other information sources to confirm the
identity of new customers or incorporating fraud detection software. Groups
with a low risk for identity theft may have a more streamlined program – for
example, simply having a plan for how they’ll respond if they find out there
has been an incident of identity theft involving their business.”
The entire press release reflecting chairman Leibowitz's comments
may be viewed by clicking on:
http://www.ftc.gov/opa/2010/12/redflags.shtm
For your convenience you may access a very informative publication
released earlier in the year by the FTC detailing the Red Flags Rule by
clicking on: http://www.ftc.gov/bcp/edu/pubs/business/idtheft/bus23.pdf
Reprinted by permission from the Credit Research Foundation (www.crfonline.org).
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