Creditors Federal Trade Commission

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Impact of the SEC and CFTC Issuing Final Identity Theft “Red Flag” Rules

On April 19, 2013, the Securities and Exchange Commission (“SEC”) and Commodity Futures Trading Commission (“CFTC” and, together with the SEC, the “Commissions”) published final rules (“Red Flag Rules”) in the Federal...more

Amended Red Flags Rule now in effect – are you still a creditor?

The FTC’s amended definition of “creditor” within the Red Flags Rule is now in effect. The definition is narrower in scope, but under it, a franchisor may still qualify as a “creditor.” For instance, if you use a...more

SEC and CFTC Adopt "Red Flag" Identity Theft Rules

The SEC and the CFTC recently issued final rules requiring certain regulated entities that qualify as either "financial institutions" or "creditors" to adopt programs to identify and address the risk of identity theft...more

The FTC’s Interim Final Red Flags Rule: What It Means for Non-Bank, Short-Term Consumer Lenders

On November 30, 2012, the Federal Trade Commission (FTC) issued an interim final rule related to its identity theft “Red Flags Rule” that amends the regulatory definition of “creditor” to make it consistent with the revised...more

Wow! Government Amends Red Flags Rule to Make it Narrower

Congress, FTC Restrict Definition of “Creditors” who must Adopt a Formal Plan to Prevent, Detect ID Theft In journalism, the adage goes, “man bites dog” is news. The regulatory equivalent should be “government amends...more

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