Identity Theft Red Flag Rules

Rebecca L. Williams RN, JD, and Brent R. Eller, Partner, Davis Wright Tremaine, Seattle. The Federal Trade Commission (FTC) has announced the Nov. 1, 2008, compliance deadline for implementing identity theft prevention programs pursuant to the identity theft red flag rules (“Red Flag Rules”). This presentation covers the Red Flag Rules and the applicability of the requirements. Providers in general should be aware of the Red Flag Rules, should revisit their existing privacy and security compliance programs to ensure that the requirements of the Red Flag Rules have been addressed, and should take other actions to bring themselves into compliance.