Another gift for you procrastinators out there … and you know who you are!

by Keir Breitenfeld 2 min read May 14, 2009

The Federal Trade Commission announced on April 30, one day before the intended May 1 Red Flags Ruleenforcement deadline, a third extension of that deadline to August 1, 2009. It’s like showing up to class without your homework and the teacher is out sick that day….kind of. The first extension from November 1, 2008 to May 1, 2009 seems to center on the general confusion among many market sectors around their level of coverage under the Identity Theft Red Flags Rule. This latest delay seems to be a result of pushback from businesses with a lower risk of identity theft occurrences and a more "known" consumer base.

So, it looks like we have at least three more months of preparation time. This can be a good thing for all institutions regardless of their current Red Flag guidelines readiness status. Those who scrambled to get a program in place now have time to fine tune it. Those that were hoping for another extension have it. Those who still question what their program should look like or if they are even covered can look forward to some more clarifying information out soon.

Some key takeaways from the announcement:

  • The FTC announcement does not impact other federal agency enforcement deadlines dating back to November 1, 2008.
  • Specific to institutions that may have a perceived lower risk of identity theft, or businesses that generally know their customers personally, the Commission will be publishing more clarifying language and sample process (in the form of a template) to help those types of businesses comply with the Rule.

Finally, this quote from the announcement sums it up: “Given the ongoing debate about whether Congress wrote this provision too broadly, delaying enforcement of the Red Flags Rule will allow industries and associations to share guidance with their members, provide low-risk entities an opportunity to use the template in developing their programs, and give Congress time to consider the issue further,” FTC Chairman Jon Leibowitz said.

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Consumer visibility is changing Roughly 45 million Americans, or 1 in 5 consumers, are considered credit invisible or unscoreable.[1] They’re working, paying bills and participating in the economy, yet many are not fully visible during the lending process. That creates both a visibility challenge and a growth opportunity for lenders. In this Ask the Expert session, Corliss Hill, Senior Director, Inclusion and Belonging at Experian, joins Dr. Vaneesha Dutra, Endowed Professor of Finance at Morehouse College, to discuss how evolving consumer behaviors are reshaping conversations around financial inclusion and lending decisions. For lenders, visibility matters because confident decisions depend on reliable context and insight. Broader consumer signals can help institutions better understand repayment behaviors, financial stability and consumer capacity. “The benefit of banks using alternative data is that they capture a very significant and new consumer base. 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Responsible lending starts with better context For lenders, the path forward is practical and actionable. As lenders evaluate broader consumer behaviors, three priorities become increasingly important: Modernize data strategies Incorporate broader consumer signals alongside existing credit data to create a more holistic view of repayment behavior and financial stability. Engage consumers earlier Earlier intervention may help lenders better support consumers before financial challenges become more severe. Create pathways to financial access Smaller lending opportunities can help consumers establish stronger financial profiles and demonstrate positive repayment behaviors over time. The institutions that lead will be the ones that can combine strong risk practices with a broader understanding of consumer behavior. Whitepaper: Bridging the credit divide: income, risk and inclusion in consumer finance Building on the themes discussed in this Ask the Expert session, Dr. Dutra explores how demographic shifts, evolving borrower behaviors and broader consumer visibility are reshaping lending strategies and what they mean for lenders seeking to balance growth, risk management and financial inclusion. Download whitepaper Explore alternative data with Experian Experian can help lenders combine broader consumer insights with trusted credit data to strengthen decisioning, improve risk assessment and support more-informed lending strategies. With solutions spanning identity, cash flow and advanced analytics, lenders can gain a more complete view of consumer behavior and expand access to credit with greater confidence. Learn more Watch episode 1 About our experts Corliss Hill Senior Director, Belonging Business Partner, Experian Corliss Hill is a collaborative leader well-versed in working with executive stakeholders, crossfunctional teams, external partners and community organizations to design and deliver initiatives and programs that create sustainable impact. With over 25 years of extensive experience in multicultural marketing, communications, PR and inclusion and belonging initiatives, she is dedicated to advancing equitable access to financial. Her mission is to drive impactful marketing initiatives that foster meaningful change and address systemic barriers to inclusion and the communities they serve.Hill has been a part of the Experian family since 2021, and resides in Atlanta with her daughter who is a rising 11-year-old entrepreneur. Vaneesha Dutra, Ph.D. Endowed Professor of Finance and Associate Dean, Morehouse College Vaneesha Dutra, Ph.D., serves as Associate Dean in the Division of Business and Economics. With more than 20 years of experience spanning higher education, banking and real estate, Dr. Dutra’s work focuses on the racial and gender wealth gap, financial literacy and financial decision-making. She is an active researcher and consultant whose work has earned numerous grants and fellowships, including serving as the inaugural Tracy A. Pruitt Visiting Research Faculty Fellow at the Wharton School of Business. Dr. Dutra has also been named a Research Faculty Fellow for both the Center for Black Entrepreneurship and the PNC Bank Center for Entrepreneurship. [1] Consumer Financial Protection Bureau, Expanding access to credit.

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