All posts by Keir Breitenfeld
At which stage of the application process does the Red Flags Rule apply? The Red Flag Rule would apply whenever you detect a Red...
After reviewing more details around the "The President’s Identity Theft Task Force Report" (September 2008), and some of the activities surrounding it, I find...
What to do when you see a Red Flag. Your Identity Theft Prevention Program should include appropriate responses when you detect a Red Flag....
How do I know which Red Flags apply to me? The Red Flag guidelinesthat will apply to you depend on a number of factors...
There seems to be some ground-laying for follow-on Red Flag compliance guidelines to emerge either pre- or post- May 1, 2009. Whether they arrive...
It seems to me that there remains quite a bit of dispute and confusion around the inclusion of healthcare providers under the umbrella of...
During a recent real-time survey of 850 representatives of the financial services industry: only 36 percent said that they completely understood the new Identity...
I’m speculating a bit here, but I have a feeling that as the first wave of Red Flag ruleexaminations occurs, one of the potential...
I have heard this question posed and you may be asking yourselves: Why are referral volumes (the potential that the account origination or maintenance...
What is your greatest concern as the May 1, 2009 enforcement date approaches for all guidelines in the Identity Theft Red Flags...
I’ve talked (sorry, blogged) previously about taking a risk-based approach to reconciling initial Red Flag Rule conditions in your applications, transactions, or accounts. In...
Hello Red Flaggers! I’m still getting some questions from our clients these days around the FTC enforcement extension. My concern is that there seems...
We continue to receive inquiries from our clients, and the market in general, around whether they are required to comply with the Red Flag...
We get the following question quite a bit: Would the regulators expect to see a log of detected activity and resulting mitigation? Short answer:...
The Federal Trade Commission (FTC) suspended enforcement of the new Red Flag Rule until May 1, 2009. According to the FTC’s Enforcement Policy, “…during...
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