Red Flags Compliance: Fact or Fiction?
YES, Red Flags compliance is very real!
Identity Theft Red Flags Rule, 16 CFR 681.2 (d) requires you to have written and implemented your plan by November 1, 2008 but enforcement is currently in forbearance. The enforcement date is now May 1,2009:
http://www.ftc.gov/os/2008/10/081022idtheftredflagsrule.pdf
http://www.ftc.gov/bcp/edu/pubs/business/alerts/alt050.shtm
Who Needs to comply?
FTC states:
"A creditor is any entity that regularly extends, renews, or continues credit; any entity that regularly arranges for the extension, renewal, or continuation of credit; or any assignee of an original creditor who is involved in the decision to extend, renew, or continue credit. Accepting credit cards as a form of payment does not in and of itself make an entity a creditor. Creditors include finance companies, automobile dealers, mortgage brokers, utility companies, and telecommunications companies. Where non-profit and government entities defer payment for goods or services, they, too, are to be considered creditors. Most creditors, except for those regulated by the Federal bank regulatory agencies and the NCUA, come under the jurisdiction of the FTC." (Retrieved from the web address listed above)
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