Walter & Haverfield LLP

Client Alert - Summer 2009


FTC ANNOUNCES NEW ENFORCEMENT DATE FOR ITS 'RED FLAG RULE' WHICH REQUIRES BUSINESSES TO IMPLEMENT AN IDENTITY THEFT PREVENTION PROGRAM.


Today, the Federal Trade Commission (FTC) announced that it will postpone the enforcement of its "Red Flag Rule" until November 1, 2009. The Red Flag Rule requires that businesses which extend credit to consumers, by deferring payment for services, create and implement an identity theft prevention program. The Rule's definition of a "creditor" is broad and will generally encompass a wide variety of entities, such as healthcare providers (including municipal EMS providers) that defer payment obligations while patient insurance claims are pending and utility companies that use periodic billing. Businesses must now have their Red Flag program in place by the November 1st deadline.

For more information on this issue, please contact:

 

Heather B. Vlasuk

hvlasuk@walterhav.com

216-619-7843

 

R. Todd Hunt

rthunt@walterhav.com

216-928-2935

 

Amy S. Leopard

aleopard@walterhav.com

216-928-2889

Walter & Haverfield LLP
The Tower at Erieview
1301 East Ninth Street, Suite 3500, Cleveland, Ohio 44114-1821
216.781.1212 tel | 216.575.0911 fax | www.walterhav.com

The information in this Client Alert is a summary of often complex legal issues and may not cover all of the "fine points" of a specific situation or court jurisdiction. Accordingly, it is not intended to be legal advice, which should always be obtained in consultation with an attorney.

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