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
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
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
On April 10, the SEC voted unanimously to adopt a final rule requiring broker-dealers, mutual funds, investment advisers, and other regulated entities to implement programs designed to detect and prevent identity theft. The...more
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