Updates on developments in data privacy and cybersecurity
Last Friday, the U.S. Court of Appeals for the D.C. Circuit issued its opinion in litigation between the American Bar Association (ABA) and the Federal Trade Commission (FTC) over the scope of the FTC’s Red Flags rule. The Court held the ABA’s claims moot in light of recently-enacted legislation.
The Red Flags rule requires covered entities…
We recently covered the Red Flag Program Clarification Act of 2010 in a blog post and client alert. The Act was intended to narrow the scope of the Federal Trade Commission’s Red Flags rule, which imposes requirements on creditors and financial institutions to detect and deter identity theft. Prior to the Act’s passage, the…
Over the weekend, President Obama signed into law the “Red Flag Program Clarification Act of 2010.” The Act is intended to narrow the types of entities that are subject to the Federal Trade Commission’s Red Flags rule, which requires financial institutions and creditors to take certain steps to prevent identity theft. More information on the…
Last week, Congress delivered to President Obama for his signature the “Red Flag Program Clarification Act of 2010,” which is intended to narrow the types of entities that are subject to the Federal Trade Commission’s Red Flags rule. The Red Flags rule requires “financial institutions” and “creditors” to establish programs to detect, prevent, and mitigate…
