Privacy and Security Alert: Stay of Execution of Red Flag Enforcement: FTC Announces Three-Month Delay of Enforcement of "Red Flags Rule"

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Less then one day before the Federal Trade Commission (FTC) was to begin enforcement of the Red Flags Rule, the FTC announced it will delay enforcement until August 1, 2009 to provide creditors and financial institutions additional time to develop and implement the required written identity theft prevention programs.

The FTC will also be releasing, in the future, a compliance template for “entities that have a low risk of identity theft,” such as businesses that know their customers personally. The April 30, 2009 announcement by the FTC does not affect other federal agencies’ enforcement of the original November 1, 2008 deadline for other institutions, such as banking institutions.

Please see full alert for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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