1. Home
  2. |Insights
  3. |FTC Extends Enforcement Date of Red Flags Rule to August 1

FTC Extends Enforcement Date of Red Flags Rule to August 1

Client Alert | 1 min read | 05.04.09

On April 30th, in a surprising move, the Federal Trade Commission (the "FTC") extended its deferral of enforcement of the Red Flags Rule until August 1, 2009. This marks the second extension by the FTC. The Red Flags Rule's mandatory enforcement date was originally November 1, 2008. However, the FTC suspended enforcement of the Rule until May 1, 2009. The FTC explained that this second extension is in response to ongoing questions from some sectors - particularly smaller entities that are subject to a low risk of identity theft that "continue to have questions and concerns about the specific obligations they must meet and the burden of complying with the rule."1

The FTC has estimated that there are more than 1.6 million low-risk entities that will be required to comply with the Red Flags Rule.2 The Red Flags Rule requires that "financial institutions" and "creditors" that offer or maintain "covered accounts," develop and implement a program to identify, detect, and respond to identity theft (the "Program"). The FTC intends to publish a guidance to assist low-risk entities in complying with the rule.

If you are interested in learning more about Red Flags Rule policies, training, or sample language, please contact those listed below, or your regular Crowell & Moring contact.

1 FTC Extended Enforcement Policy: Identity Theft Red Flags Rule, 16 CFR 681.1
2 74 Fed. Reg. 18709, 18711 (April 24, 2009).

Insights

Client Alert | 6 min read | 04.29.26

CMS Seeks to Expand Interoperability Requirements to Drug Pre-Authorization (FAQ)

On April 10, 2026, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule (2026 CMS Interoperability Standards and Prior Authorization for Drugs, or CMS-0062-P) outlining the agency’s plans to impose new interoperability requirements on payors participating in certain Medicare and Medicaid programs. As described by the agency in a recent press release, the proposed rule “builds on” prior rulemaking by clarifying and enhancing interoperability requirements for payors’ prior authorization processes, specifically those associated with coverage requests for pharmaceutical therapies....

View All Insights