Kelley Drye's Consumer Financial Services
Practice Group has prepared a client advisory titled "FACTA Red Flag, Address Discrepancy and Information Sharing Rules Compliance — Hitting October/November 2008 Compliance Deadlines." Several federal agencies have jointly-issued new rules aimed at preventing identify theft, ensuring proper use of consumer credit information, and imposing new requirements for affiliate information sharing. Three of those rules deal with affiliate information sharing, "red flag" identify theft issues, and notice of address discrepancy. Companies have until October/November 2008 to comply with these new regulations.