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COMPLIANCE REMINDER – Red Flag Rules Delayed to November 1

August 20, 2009

Authors

Bryan Cave Leighton Paisner

COMPLIANCE REMINDER – Red Flag Rules Delayed to November 1

August 20, 2009

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

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COMPLIANCE REMINDER – Red Flag Rules Apply August 1, 2009

July 1, 2009

Authors

Robert Klingler

COMPLIANCE REMINDER – Red Flag Rules Apply August 1, 2009

July 1, 2009

by: Robert Klingler

Although some questioned if the day would arrive, the Red Flag Rules issued by the FTC, the federal bank regulatory agencies and the National Credit Union Administration go into effect August 1, 2009. The Rules are drafted broadly and will apply to many different companies, including “financial institutions and creditors with covered accounts.” Essentially, if you offer any form of loan or maintain any form of money account, you will have to comply the Red Flag Rules.

Preparing for August 1

The biggest step you should take is to prepare a Red Flag Plan. Although the Rules stress that each

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