Posts by Keir Breitenfeld

June 1, 2010 Red Flags Rule compliance deadline is just the beginning

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

FTC extends Red Flags Rule enforcement deadline…..again.

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

More clarifying language from the drafting agencies

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

FTC's Red Flags enforcement deadline extension is helping many institutions

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

August 1st deadline may be ahead of you, but certain compliance requirements are in place today

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

Address discrepancies aren't the end of the road, but they sure can be a bump in it

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

What are your thoughts?

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

Common question about the Red Flags Rule

  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

Another gift for you procrastinators out there ... and you know who you are!

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

Response to reader...

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