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URGENT UPDATE: ENFORCEMENT DEADLINE FOR |
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The FTC announced
this morning that, at the request of several members of Congress, it has
again extended the deadline for enforcing its Red Flag Rule, this time until December
31, 2010. According
to the FTC’s announcement, available at http://www.ftc.gov/opa/2010/05/redflags.shtm,
the extension will give Congress time to consider legislation “that would
affect the scope of entities covered by the Rule.” As discussed in
previous Lerman Senter memoranda, the FTC’s Red Flag Rule has encountered
significant opposition from various groups, particularly with respect to the
scope of entities covered under its definition of the term “creditor.” The House of Representatives approved a bill last October
that would exclude health care, accounting and legal firms with fewer than 20
employees from compliance with the Red Flag Rule; other businesses could be
excluded from application of the Rule on a case-by-case basis, subject to
certain conditions. However, the Senate has so far failed to act on the
House Bill. We
will continue to keep you informed of all developments relating to the FTC’s
Red Flag Rules. If you have any questions, please contact S. Jenell
Trigg (strigg@lermansenter.com
or 202-416-1090), Louis Levy (llevy@lermansenter.com
or 202-416-6748), or any of the other attorneys in our office. May 28, 2010 |
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This memorandum is intended only as a general discussion of these issues and should not be regarded as legal advice. We would be pleased to provide additional details or advice about specific situations if desired. Copyright © 2010, Lerman Senter PLLC 2000 K Street NW,
Suite 600 | Washington, DC 20006-1809 To Unsubscribe: Unsubscribe | To Update Client Info: Update Client Info |
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