January 1, 2012

CLIFTON N. MILLER – The impact of the RED FLAG CLARIFICATION ACT on the FAIR AND ACCURATE CREDIT TRANSACTIONS ACT

The Fair and Accurate Credit Transactions Act of 2003 (“the FACT Act”) directed the Federal Trade Commission (“FTC”) to promulgate rules requiring creditors to implement programs to detect and respond to so-called red flags that could indicate identity theft.  The FTC’s Red Flags Rule implementing Section 114 of the FACT Act became effective on January 1, 2008 (Federal guidelines for use by financial institutions and creditors in establishing policies and procedures to mitigate identity theft risks). Section 114 of the FACT Act (hereafter “Section 114”) directed financial regulatory agencies, including the Federal Trade Commission, FTC, to promulgate rules requiring “creditors” and “financial institutions” to implement programs to detect and respond to red flags-patterns, practices, or specific activities-that could indicate identity theft.

Client Alert – Red Flag Clarification Act

Service:

Our firm prides itself on responding to clients quickly, listening and understanding their needs and working with them to find the best solution for their unique legal issue.

Tradition:

Henry & McCord has served Middle Tennessee area for over 65 years, making it one of the oldest and most established firms in this area. Our firm is committed to keeping the traditions of our founders alive...these include reverence for the law, respect for the client and service to the community.

Experience:

The lawyers at Henry & McCord have over 150 years of combined experience. Clients receive the benefit from our vast experience and wealth of knowledge.

Location:

Businesses, residents and those seeking to either live or work in Middle Tennessee also enjoy Henry & McCord's Convenient Location.