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The "Red Flags" Rule: What Independent Schools Must Know About Complying With New Requirements for Fighting Identity Theft |
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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The views expressed in this document are solely the views of the author and not Martindale-Hubbell. This document is intended for informational purposes only and is not legal advice or a substitute for consultation with a licensed legal professional in a particular case or circumstance. |
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