FTC Extends Enforcement Deadline for Identity Theft Red Flags Rule Until June 1, 2010

Morrison & Foerster LLP

We reported earlier today that the Federal Trade Commission (FTC) appeared to be plowing ahead with the effective date of the Red Flags Rule, despite a Federal Court Order that the FTC had over-reached in its attempt to apply the Rule to lawyers. The Rule was previously scheduled to take effect this Sunday, November 1.

Just to keep us guessing, the FTC has just announced that, at the request of Members of Congress, it is delaying enforcement of the “Red Flags” Rule yet again, until June 1, 2010, for financial institutions and creditors subject to enforcement by the FTC.

Please see full update below 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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