As I’ve suggested in previous postings, we’ve certainly expected more clarifying language from the Red Flags Rule drafting agencies. Well, here is some pretty good information in the form of another FAQ document created by the Board of Governors of the Federal Reserve System (FRB), Federal Deposit Insurance Corporation (FDIC), National Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), Office of Thrift Supervision (OTS), and Federal Trade Commission (FTC).
This is a great step forward in responding to many of the same Red Flag guidelines questions that we get from our clients, and I hope it’s not the last one we see. You can access the document via any of the agency website, but for quick reference, here is the FDIC version: