Updated on July 31, 2009. Please note there are two memos in the download On October 17, 2008, we issued a memorandum explaining the above referenced federal rules. Subsequently, on October 22, 2008 and May 1, 2009, we updated the October 17, 2008 memorandum to advise you that the FTC had delayed enforcement of the Identify Theft Prevention Program (“Red Flags Rule”). The updated October 17, 2008 memorandum is posted on our website www.bmandg.com. This memorandum is to advise you that the FTC has further delayed the enforcement of the Red Flags Rule for those entities subject to FTC oversight until November 1, 2009. For further information regarding this enforcement delay by the FTC and current information regarding the Red Flag Rule, please see the attached July 29, 2009 Press Release from the FTC.

Complete Memorandum