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Agencies Release FAQs on Identity Theft, “Red Flags,” Change of Address, and Address Discrepancies Under the FACT Act
Privacy & Data Security Law Journal
August 2009
Recently, several agencies released guidance in the form of “FAQs” to address certain recurring questions regarding compliance with the identity theft and red flags rules, card issuer rules regarding change of address, and address discrepancy rules implementing Sections 114 and 315 of the Fair and Accurate Credit Transactions Act of 2003. This article provides an overview of this guidance.
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Financial Institutions Regulatory
Privacy, Data Security and Information Law
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David E. Teitelbaum
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