Client Alerts

Applicability of Red Flag Identity Theft Rules to Investment Advisers

August 03, 2009

The Investment Management Practice

On November 1, 2009, many investment advisers will be required to comply with the Federal Trade Commissions Identity Theft Red Flag Rules. The Red Flag Rules will require these covered advisers to develop and implement a written identity theft prevention program. We summarize the requirements of these rules below.

What Are the Red Flag Rules?

The Red Flag Rules were adopted by the Federal Trade Commission (FTC) and other bank agencies under the Fair and Accurate Credit Transactions Act of 2003. Their purpose is to combat identity theft in connection with the establishment and operation of certain types of consumer accounts.

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Practice Areas

Investment Management

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