As we previously discussed in Issue Nos. 115 and 122 of The GPMemorandum, the new federal “Red Flags Rule” requires certain businesses to establish written programs to detect, identify, and respond to signs of possible identity theft. The rule is aimed at reducing identity theft by making it more difficult for thieves to use stolen identity information to purchase goods or services. Enforcement was originally set to begin in 2008, but has now been delayed until December 31, 2010, although enforcement may begin earlier depending on the effective date of Congressional modification. http://www.ftc.gov/opa/2010/05/redflags.shtm.
The Franchise Memorandum