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Red Flag Reprieve: ID Theft Prevention Programs Now Due May 1

October 22, 2008
by Reece Hirsch
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The Federal Trade Commission said today that it would delay enforcement of what’s known as the "red flag" rule from Nov. 1 to May 1, 2009. The rule requires that creditors—construed to include healthcare providers that accept deferred payment—adopt programs to identify and respond to indicators of identity theft.

This delay in enforcement is limited to the Identity Theft Red Flags Rule (16 CFR 681.2), and does not extend to the rule regarding address discrepancies applicable to users of consumer reports (16 CFR 681.1), or to the rule regarding changes of address applicable to card issuers (16 CFR 681.3).

The full text of the announcement can be found here:


Reece Hirsch

Partner, Morgan, Lewis & Bockius LLP

Reece Hirsch's Health Care Privacy Law Blog offers a lively commentary on a wide range of...