Are Practices Really Exempt from Red Flag Rules?

December 29th, 2010

We received this today from healthcare attorney, Charles Key.

Clients and Friends:
According to a recent posting by the American Medical Association, President Obama on December 18, 2010 signed into law the "Red Flag Program Clarification Act of 2010," passed by both houses of Congress December 8.  According to the AMA summary, the law clarifies the application of the controversial Federal Trade Commission "Red Flags Rule" so as to apply only to creditors who, in the ordinary course of business, either (1) obtain consumer reports in connection with credit transactions, (2) furnish information to credit reporting agencies, or (3)make loans.  Most medical practices (as well as law firms, accounting firms, and other professional practices) will thus not be subject to the Red Flags Rule as clarified by the new law.  Those that are subject to the Rule must comply by this Friday, December 31, 2010.
The Red Flags Rule requires non-exempt creditors to adopt written policies designed to detect, prevent, and (where found) mitigate identity theft.  For more information, see the AMA's full posting at

CharlesCharles Key | Wyatt, Tarrant & Combs, LLP | 1715 Aaron Brenner Drive, Suite 800 | Memphis, Tennessee 38120-4367 | Direct dial (901) 537-1133 | Mobile (901) 481-3321 | Fax (901) 537-1010 |


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