August 20, 2009
Authored by: Bryan Cave Leighton Paisner
The FTC has delayed the compliance date for the Red Flag Rules, the federal bank regulatory agencies and the National Credit Union Administration, to November 1, 2009 to give companies greater time to prepare their systems and protocols. The Rules have not changed. Companies should still take proper steps to ensure compliance by the November deadline. Click here for help on steps your company can take.
Although the FTC intends to publish sample Plans for “low-risk” and “high-risk” companies (terms that are still somewhat hazy at this point), it has not done so as of yet (although it has published a helpful FAQs website). Therefore, many companies are seeking outside business and legal counsel to better understand the Red Flag Rules and to ensure their plan addresses the requirements of these new regulations.