FTC Extends Enforcement Deadline for Identity Theft Red Flags Rule Until June 1, 2010

Client Alert

We reported earlier today that the Federal Trade Commission (FTC) appeared to be plowing ahead with the effective date of the Red Flags Rule, despite a Federal Court Order that the FTC had over-reached in its attempt to apply the Rule to lawyers. The Rule was previously scheduled to take effect this Sunday, November 1.

Just to keep us guessing, the FTC has just announced that, at the request of Members of Congress, it is delaying enforcement of the "Red Flags" Rule yet again, until June 1, 2010, for financial institutions and creditors subject to enforcement by the FTC. The FTC's announcement of its decision to delay enforcement is available at: http://www.ftc.gov/opa/2009/10/redflags.shtm

We will continue tracking challenges to the enforcement of the Red Flags Rule and keep clients abreast of key developments. Please feel free to contact us if you have questions regarding the application of the Red Flags Rule to your business or organization.

Andrew M. Smith

Vanessa R. Waldref

Email Disclaimer

Unsolicited e-mails and information sent to Morrison & Foerster will not be considered confidential, may be disclosed to others pursuant to our Privacy Policy, may not receive a response, and do not create an attorney-client relationship with Morrison & Foerster. If you are not already a client of Morrison & Foerster, do not include any confidential information in this message. Also, please note that our attorneys do not seek to practice law in any jurisdiction in which they are not properly authorized to do so.

©1996-2019 Morrison & Foerster LLP. All rights reserved.