On Friday, October, 30, 2009, the FTC announced that it was delaying enforcement of its Red Flags Rule from November 1, 2009 until June 1, 2010.  The FTC said it was instituting the delay "at the request of members of Congress."  The complete announcement can be found here.

The Rule was originally scheduled to take effect on May 1, 2008, but has been extended three times before.  This extension comes amidst continued debate over the scope of the "creditors" covered by the Rule.  Also today, a federal court held that the FTC may not apply the Rule to attorneys.  In addition, the House of Representatives recently passed a bill amending the Rule to exclude medical, accounting, and legal practices with 20 employees or less.

For a complete summary of the Rule, please visit

http://www.digestiblelaw.com/datasecurity/blogQ.aspx?entry=5223&id=34.

For more information about the Red Flags Rule and how it might affect your business, please contact us with questions.

Al Gidari: (206) 359-8688
Susan Lyon: (206) 359-8002
Veronica McGregor: (415) 344-7062
Joe Cutler: (206) 359-6104