Posts by Keir Breitenfeld
by May 13, 2010,
Financial Services - Bankcard, Auto, Mortgage
Well, here we are about two weeks from the Federal Trade
Commission’s June 1, 2010 Red Flag Rule compliance enforcement
date. While this date has been a bit of a moving target for
the past year or so, I believe this one will stick. It appears
that the new reality is one in which individual trade...read more
by July 30, 2009,
Financial Services - Bankcard, Auto, Mortgage
There were always questions around the likelihood that the August
1, 2009 deadline would stick. Well, the FTC has pushed out
the Red Flag Rules compliance deadline to November 1, 2009 (from
the previously extended August 1, 2009 deadline). This extension is
in response to pressures from Congress –...read more
by June 12, 2009,
Fraud & Identity Management
As I've suggested in previous postings, we've certainly expected
more clarifying language from the Red Flags Rule drafting
agencies. Well, here is some pretty good information in the
form of another FAQ document created by the Board of Governors of
the Federal Reserve System (FRB), Federal Deposit...read more
by June 10, 2009,
Fraud & Identity Management
We at Experian have been conducting a survey of visitors to our Red
Flag guidelines microsite (www.experian.com/redflags). Some
initial findings show that approximately 40 percent of those
surveyed were "ready" by the original November 1, 2008
deadline. However, nearly 50 percent of the...read more
by June 10, 2009,
As most industry folks are aware, the FTC recently pushed out their
Red Flags Rule enforcement deadline to August 1, 2009. It is
important to note, however, that this extension does not apply to
the specific requirement that institutions with covered accounts
detect and respond to address...read more
by May 29, 2009,
Fraud & Identity Management
One of the handful of mandatory elements in the Red Flag
guidelines, which focus on FACTA Sections 114 and 315, is the
implementation of Section 315. Section 315 provides guidance
regarding reasonable policies and procedures that a user of
consumer reports must employ when a consumer reporting...read more
by May 22, 2009,
Fraud & Identity Management
What are your thoughts on the third extension to the Identity Theft
Red Flags Rule deadline? Was your institution ready to meet Red
Flag guidelines? Read More » »read more
by May 15, 2009,
Fraud & Identity Management
Does the rule list the Red Flags? The Identity Theft Red
Flags Rule provides several examples of Red Flags in four
separate categories: 1. alerts and notifications recieved from
credit reporting agencies and third-party service providers; 2. the
presentation of suspicious documents or suspicious...read more
by May 14, 2009,
The Federal Trade Commission announced on April 30, one day before
the intended May 1 Red Flags Rule enforcement deadline, a
third extension of that deadline to August 1, 2009. It's like
showing up to class without your homework and the teacher is out
sick that day….kind of. The first extension...read more
by April 24, 2009,
Fraud & Identity Management
I was recently asked in a comment, "What do we have to do to become
compliant?" Great question. There is not a single path to
compliance when it comes to Red Flags compliance.
Effectively, an institution that has covered accounts under the
Rule must implement both a written and operational...read more
