WILL YOU HAVE YOUR IDENTITY THEFT PREVENTION PROGRAM (aka "RED FLAGS" PROGRAM) PREPARED AND IMPLEMENTED BY THE MAY 1, 2009 DEADLINE?
Pursuant to the Federal Trade Commission’s (“FTC”) Identity Theft Prevention Red Flags Rule (16 .C.F.R. § 681.2) which went into effect on January 1, 2008, all financial institutions and creditors must prepare and implement a written “Red Flags” Program by May 1, 2009. The determination of whether a business or organization is covered by the Red Flags Rule is not based on a particular industry or sector, but rather on whether the activities of the business or organization fall within the relevant definitions.
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