FTC Again Delays Enforcement of Identity Theft Red Flags Rules, to December 31, 2010

Available at http://www.pillsburylaw.com/siteFiles/Publications/474224D983191E5ACD5934071B5523C6.pdf

In 2007, six federal agencies2 issued final Rules on Identity Theft Red Flags and Address Discrepancies Under the Fair and Accurate Credit Transactions (FACT) Act of 2003.3 The Rules implement Section 114 and Section 315 of the FACT Act, which specifically call for “establishment of procedures for the identification of possible instances of identity theft” and “reconciling addresses.”4 Guidelines and supplemental information were released to assist FTC-regulated entities who were originally required to comply by November 1, 2008. However, FTC-regulated entities now have until December 31, 2010 to comply. This new deadline, representing an extension of over two years from the initial compliance date, was requested by members of Congress to allow for time to clarify which industries should be covered by the rules. Meanwhile, a court has excluded attorneys from coverage, and the medical profession is seeking a similar exclusion.


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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