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Category Archives: Red Flag Rules Compliance

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Compliance (Might Be?) Required: The Continuing Saga of the Identity Theft Red Flag Rules

Posted in Red Flag Rules Compliance

It was November 1, 2007 when federal banking regulators and the Federal Trade Commission (FTC) jointly issued final rules under the Fair and Accurate Credit Transactions Act of 2003 (FACT Act). These rules established for the first time the requirements for identity theft prevention programs implemented by financial institutions and other “creditors.” Those final rules were set to go into effect one year later, on November 1, 2008. As to all financial institutions regulated by the federal banking regulatory agencies (the Federal Reserve Board, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, Office of Thrift Supervision, and the National Credit Union Administration), those final rules became effective and enforceable as planned. For other “creditors” governed by the FTC, however, enforcement has been a long tale of hurry-up-and-wait.…


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