By now, you have no doubt heard of the new Red Flags Rule, which are intended to combat fraud and identity theft.  Most businesses, health care providers and other organizations that allow payment over time will be required to implement policies to detect the warning signs (red flags) of identity theft.  These policies include a written identity theft prevention protocol.  We’re taking this opportunity to remind you that these new rules go into effect May 1, 2009.  The Federal Trade Commission offers excellent guidance on these new rules:

For healthcare providers: http://www.ftc.gov/bcp/edu/pubs/articles/art11.shtm

For other businesses and organizations:  http://www.ftc.gov/bcp/edu/pubs/articles/art10.shtm

All covered entities might find this FTC guide of interest: http://www.ftc.gov/bcp/edu/pubs/business/idtheft/bus23.pdf

If you have any questions or would like assistance with preparing an identity theft prevention policy, please contact your primary attorney at the firm.  If you are not presently represented by us, please contact Susan Maslow, Patricia Collins or Joanne Murray at (215) 230-7500.