Creditors

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

Continue Reading D.C. Circuit Decides Red Flags Litigation

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

Continue Reading Federal Trade Commission Provides Initial Interpretation of the Red Flags Clarification Act in Litigation with the American Bar Association

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

Continue Reading President Signs Into Law Legislation Narrowing Scope of Red Flags Rule

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

Continue Reading President to Sign Into Law Legislation Narrowing Scope of Red Flags Rule