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The "Red Flags" Rule: What Independent Schools Must Know About Complying With New Requirements for Fighting Identity Theft



by Thomas A. Cohn
Venable LLP - New York Office

October 21, 2009

Previously published on October 2009

The Federal Trade Commission ("FTC") has adopted a rule requiring "creditors" to take steps to combat identity theft in connection with "covered" recurring payment accounts. Known as the Identity Theft Red Flags Rule ("the Rule"), the regulation mandates that businesses and organizations defined as creditors adopt Identity Theft Programs ("Programs") to spot suspicious activity that may signal identity theft. Non-profit organizations such as independent schools are not immune from the Rule.


 

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