Compliance Blog

NCUA has confirmed for us that FCU's will not get a Red Flags compliance extension.  So, why did the FTC grants its extension? According to the Privacy Law Blog, the FTC made the decision to extend due to mass confusion.  Here's a snippet from the post:

The rules apply to financial institutions and creditors.  But, according to the FTC, many companies “indicated that they were not aware that they were engaged in activities that would cause them to fall under the FACT Act’s definition of creditor or financial institution.”  Moreover, the FTC said that companies not traditionally subject to the jurisdiction of the FTC did not follow the FTC’s rulemaking, and consequently did not become aware of their obligations under the Red Flag Rules until very recently.  The FTC also expressed concern that covered entities, to meet the fast approaching November 1 deadline, were not taking the appropriate care necessary to do a proper risk assessment and craft a meaningful red flags program.

Ignorance, once again, is bliss.

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The GAO recently released a paper that does a nice job of detailing Check 21 and its progress.  This report indicates that most consumers have accepted the technology and also that financial institutions are marching along toward implementation.

If nothing else, read the executive summary that starts on page 2 for a nice progress report.  If you have a coworker or boss that might like an update, the exec summary may be a nice thing to forward.