Health Care

FTC Again Delays Enforcement of the Red Flags Rule

The Federal Trade Commission (FTC) issued a press release on July 29, 2009, announcing another three-month delay in its enforcement of the Red Flags Rule.  The enforcement date, which had been scheduled for August 1, 2009, will now be postponed until November 1, 2009

This delay was issued in response to the House Appropriations Committee’s recent request that the FTC defer enforcement in order to minimize the impact of the Rule on health care providers and other small businesses. 

In its press release, the FTC publicized that it will increase its efforts to educate small businesses about compliance requirements and that it intends to provide additional materials and guidance to do so.  A specific link for small and low-risk entities will be set up on the FTC’s Red Flags Rule website ( to enable these entities to easily access materials that are relevant to their compliance needs.

The FTC already offers a Red Flags Rule FAQs section, which addresses many compliance and enforcement issues.  This is available at:  

The full Client Alert on the requirements of the FTC’s “Red Flags” Rule is provided at:

The FTC’s July 29, 2009, press release can be accessed at:

July 30, 2009

Related DGS
Practice Groups

Health Care

If you would like to discuss issues raised by this alert or otherwise, please feel free to contact the author, Heather Kenney at 303-892-7493, or any other member of the DGS Health Care Practice Group:

Wally Stromberg - (303) 892-7478

John Francis - (303) 892-7338

Erin Eiselein - (303) 892-7308


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