The 'Red Flags' Rule: Are You Ready?

Law360, New York (March 31, 2009, 12:00 AM EDT) -- Broker-dealers beware: Enforcement of the Federal Trade Commission’s “Red Flags” Rule (the “Rule”) under the Fair and Accurate Credit Transactions Act of 2003 (the “FACT Act”) will begin May 1, 2009.[1] Are you ready?

Because the Rule has been adopted by the Federal Trade Commission (“FTC”) as opposed to the U.S. Securities and Exchange Commission or the Financial Industry Regulatory Authority (“FINRA”) and because its application has been postponed, it does not appear to have created a lot of news in the financial press. Nevertheless, the...
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