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ARTICLE · 29 OCTOBER 2008

Red Flag Enforcement

Proskauer Rose LLP
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The Federal Trade Commission (“FTC”) recently announced that it will not enforce the new Red Flag Rules until May 1, 2009, giving financial institutions and creditors an additional six months to comply by developing and implementing a written identity theft prevention program.

United StatesCorporate/Commercial Law

FTC Suspends Enforcement Of Red Flag Rules For Six Months

The Federal Trade Commission ("FTC") recently announced that it will not enforce the new Red Flag Rules until May 1, 2009, giving financial institutions and creditors an additional six months to comply by developing and implementing a written identity theft prevention program. In an Enforcement Policy Statement released on October 22, 2008, the FTC acknowledged the uncertainty felt by many entities and some industries regarding whether they would be considered "covered entities" and thus subject to the rules. This announcement, though, does not affect companies subject to the enforcement authority of federal agencies other than the FTC.

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