New federal identity theft prevention rules go into effect on November 1, 2008 and impose some compliance obligations on apartment firms as users of consumer credit reports. The rules were published on November 9, 2007 (72 FR 63718) by the Federal Trade Commission (FTC) to implement Sections 114 and 315 of the Fair and Accurate Credit Transactions Act of 2003 (FACT Act).
NOTE: On October 22, 2008, the FTC announced that they will suspend enforcement of the new “Red Flags Rule” until May 1, 2009 to give creditors and financial institutions additional time in which to develop and implement written identity theft prevention programs. This delay however does not extend to the rule regarding address discrepancies, which applies to apartment owners as users of consumer reports. Firms are still obliged to comply with that rule as of November 1, 2008.
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