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Health Care Law
Update May 1, 2009
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CLIENT ALERT:
FTC EXTENDS
ENFORCEMENT DEADLINE FOR THE RED FLAG RULES TO AUGUST 1, 2009
In an April
30, 2009 press release, the FTC announced it will delay enforcement
of the Red Flag Rules until August 1, 2009 to give creditors
and financial institutions more time to develop and implement written
identity theft prevention programs. The previous compliance
deadline was set for today, May 1, 2009.
According to the statement issued by the FTC, Congress continues to
debate whether the provisions of the regulation were drafted too
broadly and extending the deadline would give Congress additional
time to consider the issue. The FTC also announced it will
release a template to assist entities who have a low risk of identity
theft including, without limitation, businesses that know their
customers personally.
The FTC press release announcing the commission's delayed enforcement
of the Red Flag Rules is available online at: http://www.ftc.gov/opa/2009/04/redflagsrule.shtm.
Should
you have any questions regarding the Red Flag Rules or your
organization would like assistance and/or training regarding
implementation of a written Identity Theft Program, please contact
Gregory W. Moore at (248) 988-5842 or by email at gmoore@clarkhill.com or contact
Michael W. Matthews at (248) 988-5870 or by email at mmatthews@clarkhill.com.
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To find out
more about Clark Hill and our Health Care Practice Group, visit clarkhill.com
or call 800.949.3124
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