Red Flags Rule Policy & Recommendations
What Is The FTC's Red Flags Rule?
The Red Flags Rule is essentially an identity theft prevention program required by the Federal Trade Commission for financial institutions and creditors (including mortgage brokers and lenders). The FTC moved the deadline from June 1, 2010 to December 31, 2010 "while Congress considers legislation that would affect the scope of entities covered by the Rule… [However, the announcement does] not affect other federal agencies' enforcement of the original November 1, 2008 deadline for institutions subject to their oversight to be in compliance."* All financial institutions and creditors, including mortgage brokers and mortgage lenders, must have a Red Flag Policy in place by December 31. *(See http://www.ftc.gov/opa/2010/05/redflags.shtm.)
How Does My Company Comply With The Red Flags Rule?
Implement a Red Flags Rule Compliance Program by December 31, 2010. Our Mortgage Compliance Advisors can create your policy and return it to you within 48 hours.
Get A Customized Red Flag Policy Within 48 Hours
We offer two options for you: You can either purchase the templates and fill them out yourself; or you can save yourself some time and hassle and have our Mortgage Compliance Advisors complete your Red Flag Policy for you within 48 hours. One of our advisors will contact you to obtain the few pieces of information we need about your company in order to customize your policy. Once the policy is completely customized, we will send it to you in Microsoft Word format so that it can be easily modified moving forward.
Topics in the Red Flag program will include:
- Identifying Red Flags within your organization
- Detecting and evaluating Red Flags at the client level
- Responding appropriately to the Red Flags detected
- Updating the Identity Theft Prevention Program
- Conducting Required Annual Board of Director Reporting
(The work done by MetaSource on your Red Flag Policy does not constitute legal advice. Our intention is provide you with a platform to build a policy specific to your organization. It is a good idea to have your legal counsel review the policy once it has been prepared. Only your attorney can tell you if your red flag policy meets the legal requirements set forth by the Federal Trade Commission.)