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Federal Trade Commission Provides Initial Interpretation of the Red Flags...

We recently covered the Red Flag Program Clarification Act of 2010 in a blog post and client alert.  The Act was intended to narrow the scope of the Federal Trade Commission’s Red Flags rule, which...

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Additional Briefs Filed in ABA-FTC Red Flags Litigation

We covered in a previous post ongoing litigation in the D.C. Circuit between the American Bar Association and Federal Trade Commission over the scope of the FTC’s Red Flags rule.  On January 20, 2011,...

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D.C. Circuit Decides Red Flags Litigation

Last Friday, the U.S. Court of Appeals for the D.C. Circuit issued its opinion in litigation between the American Bar Association (ABA) and the Federal Trade Commission (FTC) over the scope of the...

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FTC Announces Amended Rule on Identity Theft "Red Flags"

On Friday, November 30, the Federal Trade Commission (FTC) issued an Interim Final Rule to amend its Red Flags Rule, which requires certain financial institutions and creditors to establish programs to...

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SEC and CFTC Issue Final Identity Theft Rule

Last week, the Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) published in the Federal Register a joint rule requiring entities regulated by the agencies to...

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