Delay of Enforcement of Red Flags Rule to November 1, 2009

Today, the FTC announces its third delay of the enforcement of its Red Flags Rule.  This delay will mean that enforcement will now begin a full year later than the originally set date of November 1, 2008.  The FTC’s press release, states that the reason for the delay is to provide FTC staff time to “redouble its efforts to educate [small businesses and other entities] about compliance with the ‘Red Flags’ Rule and ease compliance by providing additional resources and guidance to clarify whether businesses are covered by the Rule and what they must do to comply.” 

As our previous blog posting discusses, healthcare providers including hospitals, physicians, clinics, and dentists are required to have a Red Flags Rule Identity Theft Policy in place.  Ogden Murphy Wallace is happy to provide assistance in drafting your entity’s policy.  For further information please contact Elana Zana (e-mail addresses are not provided in the blog to avoid spammers). 

Along with the press release, the FTC has published FAQ’s that address how the FTC intends to enforce the Red Flags Rule as well as some additional topics.  Click here to read these FAQ’s.