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August 1st deadline may be ahead of you, but certain compliance requirements are in place today

As most industry folks are aware, the FTC recently pushed out their Red Flags Rule enforcement deadline to August 1, 2009. It is important to note, however, that this extension does not apply to the specific requirement that institutions with covered accounts detect and respond to address discrepancies related to consumer credit profiles. The original November 1, 2008 deadline is, and has been, the line in the sand for this requirement. I recommend that those institutions still working toward a compliant written and operational Identity Theft Prevention Program ensure that they have in place today a process to detect and respond to address discrepancies noted on credit profiles.