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Alerts
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Financial Institutions Must Adopt Programs Addressing ‘Red Flag Rules,’ ‘Special Rules for Card Issuers’ and ‘Address Discrepancy Rules’
September 25, 2008
On Jan. 1, 2008, new rules aimed at preventing and combating identity fraud (the “Red Flag Rules”), addressing the validity of change-of-address notifications (the “Special Rules for Card Issuers”) and dealing with mistaken dissemination of credit reports due to address discrepancy (the “Address Discrepancy Rules”) became effective. These new rules implement Secs. 114 and 315 of the Fair and Accurate Credit Transactions Act of 2003 (the “FACT Act”), which added new sections to the Fair Credit Reporting Agency (“FCRA”). The rules were proposed by the federal banking regulatory agencies, the National Credit Union Administration (“NCUA”) and the Federal Trade Commission (“FTC”), (collectively, the “Agencies”). By Nov. 1, 2008, covered institutions must adopt a program to address these new rules.
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