Final Federal Rules Require Identity Theft Prevention Programs to Be Implemented in 2008, Part 2

Originally published in Electronic Banking Law & Commerce Report, Vol. 13, Issue 7

Available at http://www.pillsburylaw.com/siteFiles/Publications/473C6833B19A365A2A33AB828D80208C.pdf

On November 1, 2008, many businesses will be expected to comply fully with new identity theft rules (the “Red Flag Rules”) promulgated by six Federal financial regulators.1 For background on these rules and requirements, please refer to Part 1 of this article in the August 2008 issue of Electronic Banking Law and Commerce Report.2 By now, most organizations subject to these requirements are actively developing and implementing their Identity Theft Prevention Programs. As organizations strive to meet the compliance deadlines, the following additional observations about the rules and current implementation efforts have been compiled.

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About John Nicholson

I'm a transactional attorney who focuses on structuring and negotiating large outsourcing transactions (both on and offshore). As part of my work, I've specialized in: - Structuring and negotiating large outsourcing transactions (both on and offshore) including IT outsourcing and various BPOs (including HRO, Facilities Management, Procurement, Finance and Accounting), large systems development and implementations; - Assisting with development of RFPs, proposal evaluation, down select, and negotiation; - US and European privacy laws, including US Safe Harbor, and state privacy and data breach notification laws; and - Privacy, security, legal and contractual issues associated with cloud computing. I'm a frequent speaker on outsourcing, privacy and security issues. Before becoming a lawyer, I was the acting IT director for a mid-size company prior to hiring the CIO and project manager for the company's Oracle Financials implementation.
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