Client Alerts

Funds with Check Writing Privileges Must Establish Identity Theft Prevention Programs by November 1st

July 24, 2008

The Investment Management Practice Group

Effective November 1, 2008, most investment companies that offer check writing privileges to shareholders will be required to have established and obtained board approval of an Identity Theft Prevention Program, pursuant to certain rules recently adopted by the Federal Trade Commission under the 2003 amendments to the Fair Credit Reporting Act. This program is part of the compliance requirements for the Red Flag Rules that were adopted by the FTC and five other federal agencies (the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of Thrift Supervision, and the National Credit Union Administration) in 2007.