FTC Announces Extension of Identity Theft Red Flag Rule Enforcement Deadline to August 1, 2009

Available at http://www.pillsburylaw.com/siteFiles/Publications/2D74D54726287C5215E448ACC34DCE45.pdf

On January 1, 2008, six federal agencies issued final Rules on Identity Theft Red Flags and Address Discrepancies Under the Fair and Accurate Credit Transactions (FACT) Act of 2003. The Rules implement § 114 and § 315 of the FACT Act, which specifically call for “establishment of procedures for the identification of possible instances of identity theft” and “reconciling addresses.” Guidelines and supplemental information were released to assist entities who were originally required to comply by November 1, 2008. Companies under FTC jurisdiction must now comply by August 1, 2009.


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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