Alert July 07, 2009

FINRA Publishes Red Flags Rule Identity Theft Prevention Program Template

FINRA has provided its members with a template for an identity theft prevention program designed to comply with the FTC’s red flags rule (16 CFR 681.2).  (The FTC red flags rule’s compliance date is August 1, 2009).  The template is an optional guide that can be customized to produce an identity theft prevention program tailored to a FINRA member’s particular circumstances.  Following the template does not guarantee compliance with the red flags rule or offer a safe harbor.  The FINRA template is available at